We offer a variable rate HELOC with daily interest changes if NYP (our index) changes. My question pertains to the billing statements disclosure for “Information About Your Finance Charges.” Because of daily rate changes we have had more than one periodic rate in a billing cycle and more than one balance which we would use to calculate the interest due before and after rate changes. How detailed should our disclosure be regarding multiple periodic rates and days counted in in our calculation of interest due?

4) Periodic rates. (i) Except as provided in paragraph (a)(4)(ii) of this section, each periodic rate that may be used to compute the finance charge, the range of balances to which it is applicable, and the corresponding annual percentage rate.