Jump to main content

# Why are there only two columns within the Projected Payments table of the Loan Estimate and the Closing Disclosure for construction only variable rate transactions?

For construction only transactions the CFPB staff provided unofficial guidance stating that the range of payments for the construction period should be represented in the first column and the balloon payment in the second column.

This is different from other variable rate transactions where, based on separate unofficial guidance from the CFPB staff, columns 1-4, 2-4 or 3-4 may display identical payments and/or ranges of payments, even 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).