Posted By: Patricia
rate change date and payment change date - 11/12/19 08:54 PM
I have never seen this before. Looking at a subsequent arm notice and the rate change date is August 27, 2019 and the payment change date is September 15,2019. When this loan originated back in 2004 the payment change date stated October 15, 2009 and the rate change date stated August 27, 2009. Is this okay? Normally, I see the rate change date 30 days before the payment change date. Reg Z has a sample subsequent notice which shows the rate change date 30 days before the payment change date. 1026.20(c)