Answer:
No - see 1026.20(a) - Comment 3
Modifying Real Estate ARM Loan-Disclosures
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Question:
On a consumer real estate ARM loan, the loan just adjusted. The officer is requesting to modify the loan and change the index, margin, and adjustment period. The request is primarily due to competitive reasons. Can we change the index, margin, and adjustment period without having to do disclosures?
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