Questions and Answers
If you have an eleven month real estate note with a balloon and a variable rate during the eleven months, would you be required to give the CHARM booklet?
No. The CHARM booklet is a requirement of Section 19 of Regulation Z (12 CFR 226.19(b)). The requirements of Section 19(b) apply only if the term of the loan is greater than 12 months.
(Posted: 08/17/2007)
