Hoping for some clarification. We are changing the date we use to determine our index for our rates on our HELOCS. Do we need to provide written notice and if so is it to be delivered 15 days prior to the effective date of the change? Is there any specific language that must be used?

Thanks

Paragraph 5b(f)(3)(v)

2. Examples of insignificant changes. Creditors may make minor changes to features such as the billing cycle date, the payment due date (as long as the consumer does not have a diminished grace period if one is provided), and the day of the month on which index values are measured to determine changes to the rate for variable-rate plans.

Since disclosing when and how the index is determined is required under 226.6, the change would still fall under the change of term requirements found in 226.9(c) which would require at least a 15 day notice.