Adjustable Payment table on Construction-Only fixed rate loan?

AVP at a bank ($247MUSA)


I have recently changed employers and have gone from C2P loans to construction only loans offered at my new employer.

I have a question about the Adjustable Payment (AP) table. The Reg states that the table is required when the periodic principal AND interest may change after consummation. In the commentary it states that it is NOT permitted to use the table unless principal AND interest change.

However, the table has a box that states interest only... (hmm)

So the question is this ... For a construction only loan with a fixed rate and interest only payments, is the AP table required? Any help would be appreciated. Thank you!


i.Adjustable payment table.

If the periodic principal and interest payment may change after consummation but not based on an adjustment to the interest rate, or if the transaction is a seasonal payment product as described in paragraph (a)(10)(ii)(E) of this section, a separate table under the master heading “Closing Cost Details” required by paragraph (f) of this section and under the heading “Adjustable Payment (AP) Table” that contains the following information and satisfies the following requirements:

Comment 1:

1.When table is not permitted to be disclosed.

The disclosure described in § 1026.37(i) is required only if the periodic principal and interest payment may change after consummation based on a loan term other than a change to the interest rate, or the transaction contains a seasonal payment product feature as described in § 1026.37(a)(10)(ii)(E). If the transaction does not contain such loan terms, this table shall not appear on the Loan Estimate.