We have an unsecured personal line of credit that has a variable rate (say Prime + 1) during the draw period; and will be fixed at Prime + 2 during the repayment period. In the account opening table, we show the APR for the Draw Period and an APR for the Repayment Period based on today's Prime Rate. Is that correct? We also state that the Repayment APR will be set at the start of the repayment period based on the then current Prime. The Penalty Rate is 6.0% increase over the rate in effect at the time of default. How should this be shown in the Account Opening Table? The commentary says to show a rate or a range of rates (or the highest rate). Do we show the Penalty APR based on today's rate? As Prime changes, so will the default rate.