We're decreasing the current floor on our home equity line of credit products and I question whether new initial disclosures are required from a REG Z stand point....I say to change them because the lower floor looks better when comparing other HELOC plans to ours, but could not find anything that says it's a REG Z requirement......

We have pretty much taken the opinion that a beneficial change to the customer does not require a subsequent notice. As a customer service/marketing function I think it would be wise to let your customer know about the change. Certainly disclosures for any new loans should reflect the lower floor.

Double check your HELOC disclosures for compliance with 226.5(b). By adding or changing a floor rate you could create a situation where the index plus your margin is below the initial rate based on the floor which requires additional disclosures.