98% of our HELOCs are a variable rate, discounted Plan A loans. The other 2% are fixed rate, non-discounted Plan B loans. Since the majority of the HELOCs are Plan A can we give the Plan B customers the Plan A initial disclosure or do you need a separate Plan B initial disclosure? Our software company is saying we can use the Plan A disclosure for all HELOCs but I want to be sure. Thanks.

I would say you need both disclosures, I'm basing my answer on 226.5b(d)(6)and (12).

Thank you for your reply. I also checked with the FDIC and they said I needed two disclosures. I have asked the software company to prepare a disclosure using G-14B as the sample.