Hi,

I have some confusion on how to disclose the historical table on Important Terms. Reg. Z requires the historical table must be based on the most recent 15 years of index value. If the plan uses SOFR as the index and it consists 10 years draw period and then 20 years repayment period, since SOFR was introduced in June 2017, which is less than 15-year history, should we assume the plan start in 2017 and just disclose the info from Year 2017 to 2024 with only the draw period on the historical table? Or should we disclose the info from Year 2010 to 2024, where putting "N/A" between Year 2010 and 2016, then disclose draw period between 2017 and 2019, and then repayment period between 2020 and 2024?

Paragraph 40(d)(12)(xi)
1. Index movement.

If the values for an index have not been available for 15 years, a creditor need only go back as far as the values have been available and may start the historical example at the year for which values are first available.

Thanks Randy.