We currently have a HELOC product that is Prime plus a margin. Management would like to offer a HELOC that is just Prime if all borrowers have a credit score of a certain amount or above. This rate would be for the life of the HELOC product, even if a subsequent event would uncover that the borrowers scores are now lower. With regards to the HELOC application disclosure, would this be considered a discount to our standard product and disclosed as such or should it be disclosed as a separate product?

Having a product that might involve only a separate margin would not trigger it being considered a separate plan for early disclosure purposes.

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.