The ARM notice is giving a customer major heartburn

Question:

A customer just received her initial ARM adjustment rate notice, and is kind of flipping out. She thought she was paying a lot more toward principal, and with the rate now adjusting up, she is even more dismayed to see how much will be going to interest. Do we HAVE to break down the principal and interest amounts on her ARM notice, or may we just say the total projected amount?

Answer:

It depends. Reg Z 1026.20 rules apply here, and they are a bit complex. There are two types of ARM Notices that must go out at different times, and they each have their own content requirements.
The initial notice is due 210-240 days before the first adjusted payment is due. See 1026.20(d) and Sample forms H-4(D)(3) and (4) in Appendix H.
- The changed-payment rate adjustment notice is due 60-120 days before the first adjusted payment is due. See 1026.20(c) for those rules, along with sample forms H-4(D)(1) and (2) in Appendix H.

From a practical standpoint, even if you are permitted to give just state the total payment amount in some cases, it is usually easier to adopt the same consistent format and breakdown the payment all the time. Join the webinar “Variable Rate Compliance in a Rising Rate Reality” on August 20, 2024 to learn more!

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Learn more about Rebekah Leonard’s Variable Rate Compliance in a Rising Rate Reality webinar.