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#1558842 - 06/01/11 12:22 PM Reg Z APR tolerance
OldSchoolBanker Offline
Platinum Poster
Joined: May 2005
Posts: 662
FL
My question is about adjustable rate loans like the 5-1 or 7-1 ARM products where the initial rate and payment are fixed for the initial period, then adjust annually.

Are these types of ARM products considered irregular transactions and subject to the 0.25% tolerance or are they subject to 0.125%?

I am confuised by 226.19 and 226.22.

Thank you for your guidance.
regards,
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Old School Banker

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Lending Compliance
#1558875 - 06/01/11 01:29 PM Re: Reg Z APR tolerance OldSchoolBanker
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,883
Bloomington, IN
If you search using +irregular +transaction and Richard Insley's user name you will find several discussions. Here's one to get you started.
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The opinions expressed are mine and they are not to be taken as legal advice.

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