Subsequent to our previous changes to Cx4174 (see http://www.docutechcorp.com/document-updates-md-loan-commitment-cx4174), we have been apprised of issues with the way in which the interest rate is being disclosed under these changes. While there is not a compliance issue in the way the interest rate is disclosed in the section (when properly configured), we have concluded that the previous interest rate section does a better job of disclosing “the effective fixed interest rate or initial interest rate that will be applied to the loan” (Md. Code Ann., Com. Law § 12-125[c][i]) and mitigates any issues clients may have with investors and/or auditors as to whether the disclosed interest rate is the final one or is still subject to change.
We have, therefore, changed the interest rate section back to what it was before the last changes to the document were made. This change took effect on September 30, 2014. If you have any questions or concerns about this change, please contact Client Support at 1.800.497.3584.
October 7, 2014