Different verbiage is required based on different terms of the loans, so our computations use a flag to identify the specific conditions for the account:
G = Greater than 36 month term
L = Less than 36 month term
N = No amortization (interest only)
Z = Zero balance

The reg. specifies which sections and which disclosure lingo is required for G, L and N. On zero balance loans the only thing required will be the credit counseling sentence (no Late Payment Warning or Minimum Payment Warning sections).

A few rules of thumb:

• If the minimum payment results in an estimated payoff less than 2.5 years, we do not list the second line (3 years) or cost savings (note it will be listed as 3 years for minimum payment time).
• If the minimum payment results in an estimated payoff that is greater than 2.5 years, we round to 3 years.
• If the minimum payment results in an estimate that is equal to 36 months, we are not displaying the second line or cost savings estimate as the cost savings would be $0.
• If there is a $0 balance or 0% rate on the loan, the minimum repayment warning will not display. 
• We add late fees to the principal balance regardless of configuration options prior to calculation. Since the Regulation is silent on this point, we took a conservative approach.

Examples: 

• If we estimate that the loan will pay off in 32 months, we will not display the second row or cost savings.
• If we estimate that the loan will pay off in 40 months, we will round down to 3 years and list the second row.
• All calculations are done in months but for display purposes we must round to years.