When a consumer applies for an ARM, the creditor must provide a variable-rate program disclosure:

Under Regulation Z, when a consumer applies for an ARM, the required variable-rate program disclosures must be given when an application form is provided or before a nonrefundable fee is paid, whichever is earlier.

“The disclosures required… must be given at the time an application form is provided or before the consumer pays a nonrefundable fee, whichever is earlier.”

— 12 CFR § 1026.19(b)(1)