I am trying to think over all the recent Reg. Z changes and how they would impact a new product that my lending folks want to offer ... a closed end, consumer variable rate loan that would NOT be secured by any real estate. Most likely, it would be secured by a CD, savings account or unsecured. It would definitely by closed-end without any additional advances allowed. Also, the payments would change as the rate changes. The rate would be based on an index.

The new MDIA rules don't cover it b/c it's not real estate secured. The "Credit Card" rules don't cover it because it's not open ended. There are no subsequent disclosures like an ARM b/c it's not real estate secured ... Am I missing anything?

If CD or savings secured, you will need to add a disclosure to the TIL which states that the APR does not include the required deposit. If your folks use LaserPro for documents, there is a box they would check next to the words "required deposit."