We have been working on revising our ARM disclosures to remove the 15-year historical example since it is no longer required and including the payment example since Reg Z permits us to do either. However, the question has come up on whether we can do the same for the HELOC product. I'm reading through 226.5b(f)(12) and cannot find where we have this choice on a HELOC. Do we have the option of disclosing either on a HELOC? Thank you for your help.

No. You must still disclose the historical example for HELOCs.

Dan - can you give me any history on why it may have been changed from the ARM but not the HELOC? I know I am going to get asked so just trying to be prepared. Thanks.

Sorry Brody, but I really can't give you a history of why the requirements were changed for ARMs and not for HELOCs. Maybe Richard Insley, the gurus guru for Reg. Z will see this and he can shed some light on it.