When the Fed amended Section 226.19(b) of Reg. Z to make the 15 year historical example optional, many banks dropped it in favor of the simpler 'worst case' example. If you're an ARM lender, how do you handle this?

Using the simplified worst case example makes the process so much simpler to recalculate annually. The disclosure for a product with discount, premium and fully indexed is a double sided piece of paper that takes all of 15 minutes to recalculate annually.

When using the simplified version for an ARM, is it necessary to recalculate the payment example yearly?

I know we have to for the historical example on a HELOC. We have to use the most current rate.

I am trying to talk my lending group into going with the "worse case" disclosure versus the historical data we now use, which is cumbersome. I however, can't find the reference in 226.19 b that allows this. I know there was an amendment but can't even find in the Federal Register. Can anyone help me??

Nevermind, I found what I was looking for,thanks.