Skip to content

Updated Index for Discounted Rate on ARM Product

Answered by: 

Question: 
We offer a discounted rate with some of our ARM products. We use the index at the time the rate was set to calculate the fully indexed rate throughout the entire loan and that is what is disclosed on the LE and CD. Under what circumstance would we locate an updated index from a the date of closing or within 45 days of closing and disclose a blended APR. Would this be a 2 time construction closing? We disclose based on once the rate/index is locked that is the rate/index we use when we close. Unless of course the loan is re-locked for any reason.
Answer: 

This is a complex question it would take a dozen questions to figure out what you really mean is going on with the product. About the best we can do is refer you to:

Official Interpretation
17(c) Basis of Disclosures and Use of Estimates
Paragraph 17(c)(1)

See Comment 10

First published on 02/17/2019

Filed under: 

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics