Question of the Week

  • QUESTION: When does a bank need to provide the ARM Notice of Change?

    ANSWER:  For initial rate adjustments, the notice must be sent at least 210 days but no more than 240 days before the new payment due date. If the first adjustment is prior to 210 days following closing, this disclosure would be provided at closing.                            

    For subsequent rate adjustments, the notice must be sent at least 60 but no more than 120 days before the new payment due date.  Note: The notice timing is measured by the new payment due date at the adjusted rate, not the rate change date itself.  Reference:  12 CFR 1026.20(c)(2) and 1026.20(d).  Q&A provided by TIB Bequeaith Banking Solutions.


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