32. Does the requirement that adjustable-rate mortgages be underwritten at no less than the maximum rate in the first five years prohibit Applicants from making such loans for which the rate may increase in less than five years?

No, an Applicant that offers adjustable-rate mortgages with a rate that may adjust in less than five years may do so and remain eligible for CDFI Certification so long as it underwrites the mortgage at no less than the maximum rate permitted by the loan in the first five years. For examples of how to determine a mortgage loan product’s maximum interest rate during the first five years, see CFPB’s official interpretation of Paragraph 43(e)(2)(iv) of 12 CFR § 1026.43.