TOPIC: Reg Z

Verbiage in the Payment section on an ARM Promissory Note

VP at a bank ($244MUSA)
Has anyone else had issue with this product and issue with regulators picking at verbiage within the Note itself?  If the promissory note explains how the origination rates work and how any future rate changes works (which infers whether the initial rate is at a discount or a premium), is it REQUIRED that the actual words such "the initial discounted rate" or the "initial premium rate" be included (..in the Payment section)? We are under the microscope by FDIC for not having that specific verbiage in the body of the NOTE even though our initial disclosures clearly state it. Since this seems to lean towards a Reg Z issue with FDIC, we whole heartedly disagree.  The NOTE is a legal document and is not governed by any specific compliance rules (i.e. Reg Z).  We do not think the verbiage is required. We use a reputable loan software product (LaserPro). We contacted a rep who in turn said that verbiage is not part of their hard programming on this product.  We are not sure if FDIC is unhappy with LaserPro?  Anyway...any input on what your experiences might be and how it was rectified would be appreciated.  It just seems odd to me that after years of being audited and examined, no third party has ever had issue with our bank on this.