If using 7(b) -- do you have to itemize financed start-up costs on the first statement under "Fees"?

1026.7(b)(6)(iii) Fees. Charges imposed as part of the plan other than charges attributable to periodic interest rates must be grouped together under the heading Fees, identified consistent with the feature or type, and itemized, and a total of charges, using the term Fees, must be disclosed for the statement period and calendar year to date, using a format substantially similar to Sample G-18(A) in appendix G to this part.

Even if delivering a periodic statement optionally under .7(b), I think this still applies.

7(a)(6)(ii) Other Charges
1. Identification. In identifying any other charges actually imposed during the billing cycle, the type is adequately described as late charge or membership fee, for example. Similarly, closing costs or settlement costs, for example, may be used to describe charges imposed in connection with real estate transactions that are excluded from the finance charge under §1026.4(c)(7), if the same term (such as closing costs) was used in the initial disclosures and if the creditor chose to itemize and individually disclose the costs included in that term. Even though the taxes and filing or notary fees excluded from the finance charge under §1026.4(e) are not required to be disclosed as other charges under §1026.6(a)(2), these charges may be included in the amount shown as closing costs or settlement costs on the periodic statement, if the charges were itemized and disclosed as part of the closing costs or settlement costs on the initial disclosure statement. (See comment 6(a)(2)-1 for examples of other charges.)

Thanks -- can you help me understand why .7(a) applies if relying on 7(b). I find these requirements incredibly complicated!

Well, I am not sure that they do, but 7(b) really does not contemplate real estate related closing costs. I am not sure why a lender would opt for the complicated 7(b) requirements over the simple 7(a) requirements for a HELOC. So, I have not spent a lot of time analyzing this question