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Update Home Equity Disclosure w/Change Rate Index?

Question: 
Do Home Equity Disclosures have to be updated with the change in the index rate or do you just do one annually?
Answer: 

by Randy Carey:

Paragraph 40(d)(12)(xi)

1. Index movement. Index values and annual percentage rates must be shown for the entire 15 years of the historical example and must be based on the most recent 15 years. The example must be updated annually to reflect the most recent 15 years of index values as soon as reasonably possible after the new index value becomes available. If the values for an index have not been available for 15 years, a creditor need only go back as far as the values have been available and may start the historical example at the year for which values are first available.

Answer: 

by Dan Persfull:

We only update our disclosures annually or if there is a change in the program.

First published on 07/29/2018

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