A HELOC variable rate product is based on prime + 0% margin with a floor of 4.75%.

I'm reviewing an ad for the product & am curious about section 1026.16(d)(2) which states:
(2) Discounted and premium rates. If an advertisement states an initial annual percentage rate that is not based on the index and margin used to make later rate adjustments in a variable-rate plan, the advertisement also shall state with equal prominence and in close proximity to the initial rate:

(i) The period of time such initial rate will be in effect; and

(ii) A reasonably current annual percentage rate that would have been in effect using the index and margin.

Since we're advertising the floor of 4.75% & not the current prime rate, do I need these additional disclosures?

Thanks.

There would be no way to disclose this on a floor rate, even if you had to. You can't predict when prime will go above 4.75%.

A floor rate is not a discounted or premium rate. Discounted and premium rates are initial rates held at a certain place for a certain time period. Your floor is still indexed based on prime, it just happens to be that prime is below your floor rate.

We have this same situation. The floor rate will be the low APR (not the index plus margin). Using the example above, we state, "Rates as low as 4.75% APR. This is a variable APR indexed to Wall Street Journal Prime plus a margin determined during the credit review process." The 4.75% is the floor, not the index + margin. Should we include a statement to show that the advertised rate is the rate floor? Or, show the indexed rate (3.25%) "subject to a floor rate of 4.75%"?