Ready Reserve Line of Credit

I am looking over some of the new TIL disclosure requirements and have a question regarding our Ready Reserve line of credit accounts. We offer a Ready Reserve line of credit attached to DDA accounts that are treated basically as loans (not as the "bounce protection" products talked about recently). Are we subject to the new TIL disclosure requirements? (Prompted by Bankruptcy reform which includes a warning about making only the minimum payment and also provides 2 examples based on whether the minimum balance is 4% more or less of the minimum balance.) Also, it mentions making this information available by telephone. We are a small community bank, and when customers call they talk to a live person. Are we required to disclose these minimum payment requirements in some type of phone recording? Is it correct that this requirement applies to HELOCs? Will it apply to our overdraft Ready Reserves? (FYI...on these RR, we require 5% of the balance payment per statement cycle).