Variable Rate????

Posted By: mzachau, CRCM

Variable Rate???? - 12/09/08 09:56 PM

We are offering a loan product where the borrower will receive a rate for the first five years, then adjust to a higher rate (ex: 5.25 to 6.25)for the remainder of the term. The rate adjustment is fixed and is not based on an index. Would this still be considered an ARM loan requiring Adjustable rate disclosures?
Posted By: David Dickinson

Re: Variable Rate???? - 12/09/08 10:00 PM

Refer to the Commentary to 226.17(c)(1) #11.