Can someone confirm that early ARM disclosures are only required on open ended loans and not closed end?

No, because that it isn't true. ARM stands for "adjustable rate mortgage" and has nothing to do with whether the loan is open end or closed end credit. It has to do with whether you have a fixed or adjustable/variable rate loan.

I'm assuming that you're referring to the loan program disclosure that is required for ARMs at the time of application. You are correct that only applies to closed end credit under 1026.19(b)(2).

There is no requirement for the same kind of adjustable rate early disclosure on open end credit. However, there is the requirement for the HELOC program disclosure at the time of application if the open-end credit is home secured.

anoi: I know you've got your answer, but this room is for HMDA questions. It would be better if you would post this question in the Lending forum. Thanks.

oops. I thought I selected the right Reg. Sorry David. I will keep an eye out in the future. And yes, I did get my answer. Thank you