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Reply To: TRID Clarification on disclosing CP loans

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#11828

Chris
Participant

Michelle, we are doing a similar product (testing mode at present) through LaserPro. Ours is a 5/1 ARM, one year of interest only payments, followed by 48 months of P&I payments – so that is the first 60 months at one rate, and then after that point, the rate can change annually for the remaining 300 payments.

On our LE & CD, the product description is:
1 year interest only, 5/1 Adjustable rate

I am of the same opinion as Jack – the ARM portion of the description should read 7/1, not 6/1, if the first year (interest only) is part of the first 7 years at the initial rate.