We are offering 7 year and 10 year student loans. For the application disclosure, in the LOAN COST EXAMPLES table, can we use a representative example or must we adjust it to reflect the actual term applied for?

I looked at 1026.47(a)(3) &(4) it appears that it refers to the specific term of the loan, but then reading further you can base the total paid on $10,000 which might not be the amount they are actually applying for.

Here is the cite
(3) Repayment terms. (i) The term of the loan, which is the period during which regularly scheduled payments of principal and interest will be due.

(ii) A description of any payment deferral options, or, if the consumer does not have the option to defer payments, that fact.

(iii) For each payment deferral option applicable while the student is enrolled at a covered educational institution:

(A) Whether interest will accrue during the deferral period; and

(B) If interest accrues, whether payment of interest may be deferred and added to the principal balance.

(iv) A statement that if the consumer files for bankruptcy, the consumer may still be required to pay back the loan.

(4) Cost estimates. An example of the total cost of the loan calculated as the total of payments over the term of the loan:

(i) Using the highest rate of interest disclosed under paragraph (a)(1) of this section and including all finance charges applicable to loans at that rate;

(ii) Using an amount financed of $10,000, or $5000 if the creditor only offers loans of this type for less than $10,000; and

(iii) Calculated for each payment option.

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We are offering 7 year and 10 year student loans. For the application disclosure, in the LOAN COST EXAMPLES table, can we use a representative example or must we adjust it to reflect the actual term applied for?

What do you mean? Do you have to give them payment examples for your 7 and 10 year products - the answer is yes.

Yes, so depending on what term they are applying for, the application disclosure must reflect that term. For some reason, the decision was made that the application disclosure just had to reflect an example, not something based on the actual terms applied for. Kind of like the HELOC early disclosure was what they were thinking. My thought was that the application disclosure has to be based on the ACTUAL TERMS applied for.

Kind of like the HELOC early disclosure was what they were thinking.

Your HELOC disclosure are required to reflect the terms that you are actually offering also. If the terms of your HELOC products are different, such as 5 or 15 years, that would require two separate examples in the disclosures also.