What is the difference between a "discounted rate" under 1026.16(d)(2) and a "promotional rate" under 1026.16(d)(6)?

We offer a discounted fixed rate for the first 6 months of our HELOCs, which subsequently adjusts to the current index + margin. Would this only fall within (d)(2), or does (d)(6) apply as well?

Thank you.

I would like to resurrect this post. We are going to begin offering a HELOC with an intro/discount/promotional rate for the first 12 months, then the rate will convert to a variable rate based on Prime. Reg Z says that a discounted rte is one not based on the index and margin used to make later rate adjustments, therefore, ads must show with equal prominence and close proximity to the initial rate the time period the initial rate will be in effect and a reasonably current APR that would be in effect using the index and margin. Then, a promotional rate is where the APR is not based on the index and margin that will be used to make rate adjustments under the plan, if that rate is less than a reasonably current APR that would be in effect under the index and margin that will be used to make rate adjustments under the plan. That requires the period of time the promotional rate will apply and any APR that will apply under the plan. What we are doing seems to fall under either but if it is defined as a promotional rate, how can any APR that will apply be disclosed when we don't know what the APR will be and it could change daily??? What am I missing???

You disclosure the current index plus margin as the current non-discounted rate.

Thanks Randy!!!