Questions and Answers
We offer tiered variable rate HELOC loans: Prime, Prime +1 and Prime +2. Does the historic example (specifically margins) on the HELOC disclosure need to be specific to the loan?
No. Regulation Z’s Commentary states that you are allowed to select a representative margin that you have used with the index during the six months preceding the preparation of the disclosures. You must state that the margin is one you have used recently. You can continue to use that margin until the next annual update of the most recent 15 years of index values.
(Posted: 07/18/2008)
