Sliding into a new role at my institution. Now have the job of figuring out why we do things the way we do, and if there are any issues. Guess that's everyone's job, I'm just feeling the burden especially right now. Hope this is a simple one and I'm just over/underthinking.

In any event, we offer unsecured fixed-rate installment loans. Whereas with our open-end credit plans, we disclose upfront the total of payments, on our fixed-rate installment loans, we don't. We do disclose the amount of each monthly payment (they remain constant each month) and the number of payments, so a consumer could readily calculate the total of payments, we just aren't, I guess, doing the multiplication for them. Being lost in 1026.18, is this OK?

Whereas with our open-end credit plans, we disclose upfront the total of payments, on our fixed-rate installment loans, we don't.

I am confused. How can you disclosure the total of payments on an open-end loan when you have no idea how much is going to be drawn?

The total of payments is a component of the closed-end Truth-in-Lending disclosure.

This may or may not help. The credit lines have promotional rate features. One product's no interest if paid off within a promotional period; if not, the remaining balance goes to X%. There, we're saying what the monthly payment is while APR is O% in order to pay the line off before the remaining balance goes to X%. The other product is a low APR if paid off within the promotional period, if not, the remaining balance is charged a higher APR. We suggest what payment is needed to pay off the balance within the low APR promotional period.

It also may help to know that the stage of the transaction I'm discussing is where we're showing applicants the offers they pre-qualify for, so after application.

It occurs to me that maybe this all fits in under the different advertising rules for closed- and open-end credit, in which case maybe there's no issue at all.

You do not...and can not...disclose a "Total of Payments" for an open-end revolving credit plan. If it's truly open-end, then the consumer can draw all, some, or none of the credit limit for a time period of any length. Under these conditions, you can't know what the payments will be in advance because you have no idea what the balance will be.

Section 1026.18(h) requires you to disclose the Total of Payments in closed-end credit transactions and defines that value to be the sum of the complete payment schedule.