On a 5/1 ARM, why does the 2011 TIL say "MAXIMUM during FIRST FIVE YEARS" when the payment actually adjusts at the beginning of the sixth year?

Please reference page 12 of the interim rule published on December 22, 2010: http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20101222a1.pdf. The relevant portion is quoted below:

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Maximum interest rate during first five years. The Board is revising § 226.18(s)(2)(i)(B)(2) to clarify the rule’s application to adjustable-rate transactions that are “5/1 ARM” loans. As adopted in the September 2010 Interim Rule, § 226.18(s)(2)(i)(B)(2) requires disclosure of the maximum possible rate at any time during the first five years after consummation and the earliest date that rate may apply. As noted above, some commenters questioned whether the Board intended creditors to disclose the first adjustment for “5/1 ARMs” under this provision. Commenters stated the  intent of the rule is unclear because the first rate adjustment generally occurs more than five years after consummation. For example, assuming a “5/1 ARM” loan is consummated on August 16, 2011, the first payment due date typically is October 1, 2011. The first rate adjustment then occurs on the due date of the 60th regular payment, September 1, 2016, which is more than five years after consummation. The Board intended that creditors disclose the first rate adjustment for a “5/1 ARM.” To ensure that the first rate adjustment will be disclosed for “5/1 ARMs,” the Board is revising § 226.18(s)(2)(i)(B)(2) to clarify that creditors should disclosure the maximum possible rate that will apply at any time during the first five years after the date on which the first regular periodic payment will be due, rather than after consummation.

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