230 R.I. Admin. Code 40-10-3.5(B)(2)(a)(1) states:
New Monthly Payment: The Applicant's/borrower's new monthly payment(s) must be lower than the total of all monthly obligations being financed, taking into account the costs and fees as disclosed on the Closing Disclosure Form. The “new monthly payment” on any loan product other than a conventional fixed rate mortgage would be the payment that fully amortizes the mortgage loan over the term of the loan at the highest rate of interest that may be charged under the contract over the term of the loan. Costs and fees as disclosed on the Closing Disclosure Form shall include all costs and fees regardless of whether incorporated into and financed through the subject loan. The “taking into account” and time for recouping of such costs and fees shall be calculated over a period of twenty-four (24) months and said amount should be added for the calculation of the final “new monthly payment” for purposes of R.I. Gen. Laws § 34-25.2-4(q)(1).
To support this 24-month calculation in our Cx11242 RI Tangible Net Benefit Form, we have created the following fields:
FI 194044 Rhode Island Tangible Net Benefit Imported Proposed Payment
FI 194045 Section J Total Divided By 24
FI 194046 Rhode Island Tangible Net Benefit Calculated Proposed Payment
FI 194047 HELOC Rhode Island Tangible Net Benefit Calculated Proposed Payment
These new fields will impact the second (lower) monthly payment amount in the "YOUR MONTHLY PAYMENT WILL DECREASE FROM:" line. The document logic first uses direct import FI 194044 “Rhode Island Tangible Net Benefit Imported Proposed Payment” if it is populated.
If FI 19044 is not populated, the document logic calculates the amount using HELOC (FI 194047 “HELOC Rhode Island Tangible Net Benefit Calculated Proposed Payment”) or Non-HELOC (FI 194046 “Rhode Island Tangible Net Benefit Calculated Proposed Payment”) fallback calculation logic.
The fallback calculation logic is:
HELOC:
FI 82338 “Fee Section J Borrower (or All) Total” ÷ 24 (FI 194045 “Section J Total Divided By 24”) and then added to FI 134800 “HELOC Full Draw Repayment Payment Based on Maximum APR”.
Non-HELOC:
FI 82338 “Fee Section J Borrower (or All) Total” ÷ 24 (FI 194045 “Section J Total Divided By 24”) and then added to FI 52154 “Max Amount Principal and Interest can change to”.
Because FI 97631 “Max P&I Amount” is not calculated for Non-TRID loans, FI 52154 is used for Non-HELOC calculations, and FI 134800 is used for HELOC calculations.
These changes are available for testing on Stage & Stage 2 servers and will take effect on June 5, 2026. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.
T3S-27448
DR-220501