HE Promo- Defer 1st Payment for 90 Days Incentive

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Question:

We are considering having a HE promo. The incentive is to defer the first payment for 90 days and on loan disclosures indicate first payment due 90 days out. Do any of you foresee anything non-compliant with this?

Answer:

Whether you can do this would be based on State law. It would however most likely trigger negative amortization disclosures.

First published on BankersOnline.com 3/26/12