I am in the process of reviewing our HELOC early disclosures using a OCC worksheet and it is talking about disclosing the finance charge, our current disclosures do not include this but the notes do. 1026.6 referred me to 1026.40 where I did not see it required. Any guidance would be appreciated.

What worksheet? Without reading the source of your question, how can we answer??

From the OCC's Truth in Lending Comptroller's handbook dated 12/14, worksheet 9 Open-End Home Secured Credit forms Reveiw. Question 15 asks: "Does the creditor disclose, as applicable, the circumstances under which a finance charge will be imposed and an explanation of how it will be determined, including a statement of when finance charges begin to accrue and an explanation of whether or not any grace period exists?"

Question 15 is regarding the initial account opening disclosure and not the early application disclosure. So I am not sure about your specific question.

Ok, I think you just cleared it up for me with your question. The finance charge discription is not required on the early application disclosure but is required on the initial account opening disclosure correct?

Correct.

As always thank you!