Our bank has purchased new loan software and we are in the process of making sure the disclosures are correct and the way we want them. In Kansas, consumer loans must be calculated on 365 day basis. The 15 year historical example on the HELOC program disclosure is calculating the sample payments on a 360 day basis. The software company is telling us that this is okay because it is exactly like the sample in the Appendix G of the regulation. I am thinking that the example we give our customer should be on 365 days like their loan will be. I have checked with one FDIC examiner and they agreed with me, what do the rest of you think? Also the software company has the sample payments calculating each year using the first year rate and I think that the rate should be calculated at the rate for each sample year, right or wrong? All opinions and advice will be appreciated.

This method does not square with Section 226.5b(d)(12)(xi) unless your account has a fixed rate. (Maybe it was not set up correctly for variable pricing?)

Disclosures should reflect the terms of your credit agreement, but what's the difference between 365/365 and 360/360?

Guess I needed someone to wake me up this morning. I see now that I was using 365/360 days! The other I am still working on. Thanks.