We are putting "up to 30 year fixed" in a mortgage ad.

I know it's a Reg Z trigger. We are not putting rate and it the rate will change frequently. My issue is the APR, do I need to estimate just the closing fees that we have (ie. 1% origination fee, $250 processing fee, $275 underwriting fee, and $250 document prep fee)or do I need to include the flood life of loan, CPL, settlement fee too?

If anyone wants to chime in, using a 5% rate so far I have:

The repayment term is based upon a 30 year fixed rate mortgage. For a loan amount of $100,000 with a 80% loan-to-value ratio, with an APR of _______%,the estimated payment schedule would be 360 principal and interest payments of $536.82. Payments shown do not include amounts for taxes and insurance, actual payment obligation will be greater.