The HELOC program disclosure is given with the application. If there is a rate change (or floor/ceiling change) between application and closing, how should this be disclosed? Specifically, if the floor decreases, could a new HELOC program disclosure be given to the customer prior to closing? While we are researching, would like to know how it would be handled for increases and decreases.
Are there specific timing requirements if re-disclosing prior to closing?

Thanks! Open-end is confusing.

Do you give a time frame on your HELOC application disclosure? Or do you disclose that the terms may change at any time?

40(d)(2) Conditions for Disclosed Terms
Paragraph 40(d)(2)(i)
1. Guaranteed terms. The requirement that the creditor disclose the time by which an application must be submitted to obtain the disclosed terms does not require the creditor to guarantee any terms. If a creditor chooses not to guarantee any terms, it must disclose that all of the terms are subject to change prior to opening the plan. The creditor also is permitted to guarantee some terms and not others, but must indicate which terms are subject to change.

An interest rate change based on an index value is not an issue. A change in the floor/ceiling is a different program, if you are quoting a hard floor/ceiling.

A creditor that receives a request for information about other available programs must provide the additional disclosures as soon as reasonably possible.