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Initial Rate Adjustment Disclosure – Date of Disclosure

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  • #5754
    tstrait
    Participant

    Initial Rate Adjustment – Content ยง 1026.20(d)(2) states:

    If the new interest rate (or the new payment calculated from the new interest rate) is not known as of the date of the disclosure, an estimate shall be disclosed and labeled as such. This estimate shall be based on the calculation of the index reported in the source of information described in paragraph (d)(2)(iv)(A) of this section within fifteen business days prior to the date of the disclosure.

    What is “date of disclosure” referring to? I was assuming it was referring to the Initial Rate Adjustment Disclosure date, therefore the index used in this notice needed to be current within 15 days. We are an FIS bank, and in checking their notices, they are pulling the index that is currently on the core (i.e. the original index when the loan was booked). Their interpretation is they can use the orginal disclosure information.

    Is this right?

    #5756
    Bankoftn
    Participant

    We are an FIS bank as well so I’m interested in this response as well. Thanks!

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