I apologize if this has been discussed but I am having problem finding a straight answer. Imagine that!

For a fixed term, closed end home equity loan with principal and interest payments, only, no escrow, does the line for escrow need to show on the TIL with $0.00 or N/A in the column for the amount of the escrow payment?

I attended an ICBA webinar which stated the line must appear on the TIL and N/A should be entered. I can't seem to find this anywhere and am not interpreting the Reg that way.

Our loan software provider says that escrow line is not needed if there is no amount in the payment reserved for escrow payments.

Help! Could you point me to where I can find the answer in the reg if the line is required on the TIL? Thanks!

I don't think you will find an answer in the regulation. Our attorney advised us to keep the escrow line and fill in N/A (or $0) when there is no escrow. He felt deleting the line would probably qualify as a formatting change (which is not allowed). He also thought it was better to include a more specific statement, such as "N/A" or "Not included" because that is the way that the Federal Reserve did it in the sample disclosures in the August 2009 proposed rule, which was where the Fed first introduced the concept of the rate/payment table.