Because of system issues we are having to figure the payment examples for HELOC disclosures manually. I have thoroughly confused myself after reading 1026.40 over and over.

The HELOC program terms are Prime Rate + 5.5 margin, Intro rate 6% for 3 years, 6% floor, 18% ceiling, no other caps, and the minimum payment each month is 1.5% of the outstanding principal balance.

Since the soonest 18% can apply is in the 4th year, do we disclose the maximum payment example at:
1. 18% as if it is 18% from the start - $150 payment
2. 18% in the 4th year based on an amortization that began with the intro discounted rate of 6% - $104.20
3. 18% in the 4th year based on an amortization that began with the rate equal to Prime+5.5% (14%) - $130.43

I guess I am unsure why you are asking about amortization. The requirement is pretty clear.

The minimum payment based on the maximum rate based on an outstanding balance of $10,000 and then separately, how fast can that maximum rate be reached.

(x) The minimum periodic payment required when the maximum annual percentage rate for each payment option is in effect for a $10,000 outstanding balance, and a statement of the earliest date or time the maximum rate may be imposed.

Unlike in the historical table which is based on an amortized example.

Thanks!