Whe providing TIL disclosures on variable rate, interest only loans that are NOT secured by real estate, is it acceptable to disclose only the highest monthly payment amount in the range? I'm thinking that the general statement: "All numerical disclosures and dates, except the late charge disclosure, are estimates" would make it acceptable to only disclose the highest amount. AND/or is it acceptable to use the tabular payment schedule???

I'm having trouble envisioning a closed-end credit product where the AF and due dates need to be estimated. What index controls rate changes? What causes the discloseable payments to vary in amount?

Absolutely not!!