On the CFPB rate spread calculator for a variable HELOC that can adjust daily you would put a 1 in the years to first adjustment, correct? I realize that is one year and it is daily but believe the below exception applies. Overthinking it probably.
There is an exception for a loan term shorter than six months (including variable-rate covered loans with no initial, fixed-rate periods), which should be rounded to 1.
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CRCM