Is "interest only payments for 12 months" considered a promotional payment under the new requirements. I can't find what defines a "promotional payment".

Also, if we have that disclosed on the website in the same size font, are we okay?

my head is spinning.

Is this for an open-end credit product? If so, see 12 CFR 226.16(d)(6)(B).

(B) Promotional payment. The term ``promotional payment'' means--
(1) For a variable-rate plan, any minimum payment applicable for a promotional period that:
(i) Is not derived by applying the index and margin to the outstanding balance when such index and margin will be used to determine other minimum payments under the plan; and
(ii) Is less than other minimum payments under the plan derived by applying a reasonably current index and margin that will be used to determine the amount of such payments, given an assumed balance.
(2) For a plan other than a variable-rate plan, any minimum payment applicable for a promotional period if that payment is less than other payments required under the plan given an assumed balance.