Construction to Permanent ARM Loans
After an audit, we have adjusted the language in the Loan Estimate (Cx18565) and Closing Disclosure (Cx18566) for ARM Construction to Permanent loans when the construction rate is not the same as the interest rate. These language adjustments are based on the information contained in both CFPB TRID for Construction Loan Guides (for combined, one-transaction disclosures and for separate construction and permanent phase disclosures).
When the Loan Purpose (FI 1063) is ‘Construction to Perm’ and the Amortization Type (FI 99) is ‘Adjustable Rate’ (ARM) and the Construction Loan Interest Rate (FI 539) is NOT the same as the Interest Rate (FI 1005), then the Interest Rate disclosure in the Loan Terms sections of the LE/CD will now read:
"Adjusts once starting in __________"
The blank is populated with (year [x]) or (month [y]) as appropriate, depending on the construction term + 1 month.
Example: "Adjusts once starting in mo. 13"
Under these same conditions, we have updated the AIR Table, specifically the two lines in the "Change Frequency" sections as follows:
"First Change" line will now read:
Beginning of [Construction Term + 1 month] month
Example: "Beginning of 13th month"
"Subsequent Changes" line will now read:
[Construction Term + ARM Fixed Period + 1 month] month & every [Periodic Rate Change Months] month after
Example: "61st month & every 6th month after"
‘Month’ to ‘Mo.’ Abbreviation Change
In each row of the Loan Terms section, any time the disclosure language previously said “month”, the abbreviation “mo.” will be used instead.
Effective Date
These changes are available for testing on Stage & Stage 2 servers and will take effect on October 28, 2025. If you have any questions or concerns, please contact Client Support at 1.800.497.3584.
COM-6042
DR-184089