I really hope I'm overthinking this....

Commentary to 1026.37(a)(10)(1)(I) states that when disclosing an ARM product, the disclosure of the loan product must be preceded by the length of the introductory period and the frequency of the first adjustment period thereafter. It then goes on to provide examples of an ARM rate with an "introductory rate" that would be disclosed as a 5/3 Adjustable Rate".

The commentary then states when an ARM product has no "introductory rate" the creditor should disclose 0 where the 'introductory period " would have been listed and gave an example of a 3/3 being disclosed as 0/3 Adjustable Rate.

If you click on the imbedded link to obtain the definition of "introductory rate" the following appears:
Introductory rate means a promotional rate offered in connection with the opening of an account. Interestingly this definition of the introductory rate is referenced from1026.16(g)(2)(ii).
If the initial ARM is a 'discounted' rate is that considered an "introductory rate". What makes an initial ARM rate "introductory or promotional"?
If our initial ARM rates are being offered at Par or are a Premium rate, they would not be considered introductory or promotional?

The reference in the commentary should be to an introductory period, not rate. Then it makes sense.