Answer:
If you are covered under TRID and the rest of Regulation Z, you are not exempt. Refer to ยง 1026.19(b).
Are ARM Disclosures Needed
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Question:
As an independent mortgage banker disclosing an Adjustable Rate Mortgage, is it necessary to provide the consumer an ARM disclosure or are we covered by disclosing the Loan Estimate and Closing Disclosure which provide ARM details?
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