Ok, understood. And in our case, the initial rate is not based on the index. We currently disclose the Initial Interest Rate Discount before the Payment Example and the Payment Example reads as follows: "....For example, on a $10,000, 30-year loan with an initial interest rate of 3.65% (the initial interest rate in effect May 2021, which is not based on the index in effect for May 2021)..." Does this not comply with Reg Z because the discount is not redisclosed with initial rate not based on index in payment example? Thank you.