You'll need to set a policy for your loan officers to make sure that the first due date is no more than 45 days out, and the month you select will depend on the timing of when the new loan is opened.  For example, if a member takes out a loan on September 3rd, then the first due date could be set to September 30.  But if the loan isn't booked until September 18th, then you would set a first payment due date of October 31 instead. 

NOTE:  This, of course, assumes that the closing documents the member gets would constitute the "notification" of first payment due for the purposes of the Act.  The interpretation of this seems to be a little nebulous at the moment.  In any case, we are not making any recommendations one way or the other so please be sure to consult your legal counsel as to what your policies should be, especially in cases where other state regulations appear to overlap.