There's two sections to 226.19. Look to 226.19(b,). The Reg. Z disclosures for 226.19(b) and .5b are required for all loans secured by 1-4 dwellings that fall within the scope of that specific section. They also have different initial disclosure requirements. But the presence of a discount, or a premium, constitutes separate programs under both sections.
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The opinions expressed are mine and they are not to be taken as legal advice.