After studying countless ways to violate Sections 1026.24 and 26, I'm convinced that the best approach is to focus your energy on creating and maintaining a bullet-proof rate board on the bank's web site. Your procedure (and related training and monitoring) for responding to requests for rate quotes then becomes very simple--don't quote anything that isn't on the web page. Staff can read the information to inquirers, print it out and hand it to inquirers, or give them the URL so they can do it themselves. This single procedure works for oral, electronic, or written inquiries with oral, electronic, or written responses.
You can choose which products to include on the rate board. Nothing says you have to advertise them all, so include the ones that account for a high percentage of your originations. Low volume products can be listed as available along with an invitation for interested individuals to come to your office to discuss pricing. Hopefully, you're able to generate individualized quotes with your loan documentation software. These can be a much closer match to the inquirer's needs than the representative examples you will generate for the rate board.
ARM loans are tough to advertise correctly. Loan amounts and a few of the other product features can be estimated, but the indexes, margins, and offering rates are known for all the products you offer. Reg Z never permits you to ignore known information, so it's necessary to generate the stepped payment schedules needed to calculate the APR--even though fees and other Finance Charges have to be estimated.
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...gone fishing.