For HELOCs with maturities shorter than 15 years (7 years for example), should the 7 years of required payments shown in the 15 year Historical Example disclosure starting with the first 7 years of the table leaving the last 8 payments blank or should the first 8 payments be blank and the most recent 7 year period be shown with payments?

Home Equity Example G14B of the appendix appears to show the former.

Paragraph 40(d)(12)(xi)

8. Payment information. i. The payment figures in the historical example must reflect all significant program terms. For example, features such as rate and payment caps, a discounted initial rate, negative amortization, and rate carryover must be taken into account in calculating the payment figures if these would have applied to the plan. The historical example should include payments for as much of the length of the plan as would occur during a 15-year period. For example:

C. If the length of the plan is less than 15 years, payments in the historical example need only be shown for the number of years in the term. In such cases, however, the creditor must show the index values, margin and annual percentage rates and continue to reflect all significant plan terms such as rate limitations for the entire 15 years.

So, the payments could be shown in either place, years 1-7 or in years 9-15?

There are no payments for years 9-15 so why would you show payments for that period?

the creditor must show the index values, margin and annual percentage rates and continue to reflect all significant plan terms such as rate limitations for the entire 15 years.

For 9-15 you would continue to the show the index values, margin and the APR based on any rate caps. The monthly payments would be shown as NA.

Thanks, but maybe I'm not asking my question correctly. Our LOS (Encompass) shows the 7 payments for the last 7 years of the 15 year example (years 9-15) and leaves the first 8 years of the payments in the table blank/NA. Is that compliant?

That is not correct based on the commentary.

Thanks, Mr. Carey.

Our LOS (Encompass) shows the 7 payments for the last 7 years of the 15 year example (years 9-15) and leaves the first 8 years of the payments in the table blank/NA.

I would check the set-up to make sure the draw period and repayment periods are set up correctly.