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# Why are there columns with duplicate data in the Projected Payments table of the Loan Estimate and the Closing Disclosure?

The Projected Payments table of the Loan Estimate and the Closing Disclosure will include four columns for variable rate transactions in cases where the ceiling and the floor, along with the minimum and maximum payments, are reached during the initial period (and other limitations, such as periodic caps or the loan term, do not apply). This is based on unofficial guidance from the CFPB staff indicating that a new column is required in the Projected Payments table for loans with a variable rate each time there is a possibility during a specific time frame that the interest rate may change (and that the payment may change as a result).

With this approach, the Projected Payments table will include four columns even if columns 1-4, 2-4 or columns 3-4 display identical payments and/or ranges of payments. [12 C.F.R. 1026.37(c)(1)(i)(A) and Comment 37(c)(1)(i)(A)-1]