Is it standard for the Historical Chart to have a margin of 1% if 1% was never exceeded? Can you use 0% margin if you have only charged prime in the past?

Paragraph 40(d)(12)(xi)

3. Selection of margin. A value for the margin must be assumed in order to prepare the example. A creditor may select a representative margin that it has used with the index during the six months preceding preparation of the disclosures and state that the margin is one that it has used recently. The margin selected may be used until the creditor annually updates the disclosure form to reflect the most recent 15 years of index values.

So, yes 1% should be used even if the margin was zero?

A creditor may select a representative margin that it has used with the index during the six months preceding preparation of the disclosures and state that the margin is one that it has used recently.

Have or have you not used 1% in the last six months. There is no requirement to show a specific margin if you aren't using one. If that number is 0%, then on that is what you base your disclosures.

We have not used a margin recently, but do we need to list any margin for the corresponding year over the past 15 years if indeed we did add it?

Thank you!!!

As Randy stated you are not required to disclose a margin if one is not being used.

How have you disclosed it in the past? If you aren't changing the program then there is no reason to change the disclosure other than the required annual update.

If the program is changing and you will be using a margin then I would prepare the historical example using that margin.

We have programs ranging from a 0% margin to a 4% margin. We have disclosures for each program but the reason we do is the floor rate for each program is different therefore that floor rate affects our historical example.

I just need two separate histories. I don't know why I didn't see that before.

Thank you both.