All of our home equity products give the customer 0.25% off of the rate if they choose to have their payment automatically deducted from their bank account, and will increase back to the normal rate if they stop auto pay for any reason during the life of the loan.

Does anyone else do this type of loan and understand the best way to disclose it under TRID on the LE?

Right now, our system (LaserPro) is disclosing it as "0/Daily Adjustable Rate" product, and the disclosure bullet point under Loan Terms read "Adjusts once in day 2" for the interest rate and "Adjusts once in month 1" for Monthly Principal and Interest.

I feel like this will be MUCH more confusing to customers, especially since the Reg leaves no areas on the LE where I can explain even why their rate will increase like the prelim TIL did.

Anybody else having this problem and handling it a different way?

We are a Laser Pro user and currently offer a HEL with an auto debit discount just like you do. The rate will increase when auto debit is discontinued, and would not be subject to change again.

Our LE came out the same in all areas except our product shows a 1 day/0 adjustable rate. Honestly I was expecting to see 0/0 adjustable rate here. We can't seem to find anyway to change our set up to get this to disclose any differently. I wouldn't describe the potential rate change as an "intro period" but LPL seems to think differently.

fyi - we offer a lot loan without an auto debit discount that is tied to WSJ prime and is adjustable daily.

The product type for that shows 0/daily adjustable rate. The interest rate and monthly p&i tables are different as well - adjusts every day starting in day 2 and adjusts every month starting in mo 1.

Not sure if anything more recent has been mentioned regarding these loans, but wanted to check around and see if there is any updated information on such situations. I believe that 0/Daily Adjustable Rate seems to be the correct "Product" description for such loans. An additional nuance is what if you have an auto-pay discount as on "overlay" with a true ARM, such as a 5/1. I believe I can conceptualize how the Projected Payments table would work, but I can't conceptualize the AIR table. For the "First Change," the creditor would disclose "Beginning of 1st month" or something like that. But, for "Subsequent Changes," you would seem to be able to need to disclose "Beginning of the 61st month and every 12 months after that." Do systems generally allow complex statements like that?

Bump . . . I have seen some older threads with @RL saying to disclose a 0/0 Adjustable rate, but I believe the second part should be "Daily" similar to the "Weekly" example in the Official Interpretation.

[iii. Adjustments more frequent than monthly. For adjustment periods that change more frequently than monthly, § 1026.37(a)(10) requires disclosure of the applicable unit-period, such as daily, weekly, or bi-weekly. For example, for an adjustable rate construction loan with no introductory fixed rate period where the interest rate adjusts every seven days, the disclosure required by § 1026.37(a)(10) is “0/Weekly Adjustable Rate.”]

Also, I have seen another thread that noted an employee discount loan doesn't change based on an index or a schedule, so an AIR table is unnecessary. I agree that seems to be correct. The issue is what happens when the employee discount is part of an actual ARM loan? As I noted above, can systems handle complex descriptions in the "Subsequent Changes" row?