We are located in PA but have a borrower who lives in NY. We are making a LOC secured by the borrower's investment account. When we print the docs, the system is giving us a disclosure for a variable rate (kind of like a HELOC disclosure with a historical example). I found another thread and looked up NYCRR Title 3, Part 90, but I'm still not sure if we need to give this disclosure. 90.2 says "This Part applies to open-end accounts which are established by lending institutions and which provide for changes in the rate charged on the account from time to time but not more often than once within any three-month period." Our rate can change monthly.
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