We have a fixed rate HELOC product. In the program disclosure, Reg Z requires that we include a rate that we have used for this program in the preceding 12 months. Reg Z model disclosures do not contain any model language for making this disclosure. Our disclosure provided by our forms vendor reads as follows:
FIXED RATE FEATURE: This product is subject to a fixed annual percentage rate. An ANNUAL PERCENTAGE RATE of 5.250% has recently been imposed under this product. The annual percentage rate includes only interest and no other costs.
We now have an auditor suggesting that our disclosure verbiage be changed to include the date that this rate was imposed to make it easy to identify that it is within the prior 12 months. I think this is overkill and unnecessary. Thoughts?
Jim Bedsole, CRCM, CBA, CFSA, CAFP
My posts - my opinions