On our HELOC early disclosure, rather than state a specific floor rate (such as 5.0%), we would like to state something like: "your interest rate will not go below a floor rate that will be established at the time of loan closing." The actual floor will be based on FICO score thus would vary from customer to customer. Is that permissible? It would seem we need to be more clear in the actual floor rate in the early disclosure so the customer knows what they are getting into. In some cases, the customer's starting interst rate will be below the floor thus they will pay interest at floor rate right away.