Document Updates: New Loan Estimate (Cx18565) Field 193993 Truncate ARM Fixed Period On LE Product Description
Apr 20, 2026
The Official Interpretation of 12 CFR § 1026.37(a)(10)-3(i) states:
Terms of 24 months or more. For product types and features that have introductory periods or adjustment periods that do not equate to a number of whole years, if the period is a number of months that is 24 or greater and does not equate to a whole number of years, § 1026.37(a)(10) requires disclosure of the whole number of years followed by a decimal point with the remaining months rounded to two places. For example, if the loan product is an adjustable rate with an introductory period of 30 months that adjusts every year thereafter, the creditor would be required to disclose “2.5/1 Adjustable Rate.” If the introductory period were 31 months, the required disclosure would be “2.58/1 Adjustable Rate.”
The Official Interpretation of 12 CFR § 1026.37(a)(10)-1(i)(B) states:
Introductory period not yet known. If the loan product is an adjustable rate with an introductory period that is not yet known at the time of delivery of the Loan Estimate, the creditor should disclose the shortest potential introductory period for the particular loan product offered. For example, if the loan product is an adjustable rate with an introductory period that may be between 36 and 48 months and the rate would then adjust every year, the disclosure required by § 1026.37(a)(10) is “3/1 Adjustable Rate.”
To more closely align with the Closing Disclosure (Cx18566), the Loan Estimate (Cx18565) will now default to expressing the ARM Period by using a decimal point in the Product Description for terms of 24 months or greater which do not equate to a whole number of years regardless of Loan Type.
Previously, when the Loan Type equaled FHA or VA, the original default was to automatically truncate the ARM Period to a whole number of years in the Product Description in the Loan Estimate.
A new Field 193993 "Truncate ARM Fixed Period On LE Product Description" has been created to allow clients to choose when truncation should apply for FHA and VA ARMs in the Loan Estimate. When Field 193993 = Yes, a truncated whole year value will print in the Product Description in the Loan Estimate.
This change will have no impact for clients importing the entire Product Description with Field 91744 “Imported Integrated Disclosure Loan Product Description” or for clients utilizing the functionality in Field 109160 “Calculated Loan Product Description (LE)”.
This change is available for testing on Stage & Stage 2 servers and will take effect on April 28, 2026. If you have any questions or concerns about this change, please contact Client Support at 1.800.497.3584.
COM-7159
DR-214502
The preceding is for informational purposes only and is not and may not be construed as legal advice. No third party entity may rely upon anything contained herein when making legal and/or other determinations regarding its practices, and such third party should consult with an attorney prior to embarking upon any specific course of action.
The preceding is for informational purposes only and is not and may not be construed as legal advice. No third-party entity may rely upon anything contained herein when making legal and/or other determinations regarding its practices, and such third party should consult with an attorney prior to embarking upon any specific course of action.