Would it be permissable to respond to clients inquiry regarding mortgages using the following language?

"Our long term fixed mortgage rates start at XX.XX% APR. Your rate may vary based on term, loan amount, LTV, Credit score, Escrow status, and applicable fees. Rates are subject to change."

I'm thinking yes, and that we would not have to further disclose since we are not using any trigger. I'm I missing something here?

I think this is OK. You haven't triggered anything with this statement.

Thanks for restoring my confidence!