We anticipate coming out with an ARM product that is semi risk-based, depending on a LTV and credit score matrix. (This is somewhat based on the FannieMae Extended Approval I and II.) In short, the margin may be 2.75% 3.50% or 3.75% over the index. Reg Z indicates that a difference in margin does not constitute a separate program, and we can create one ARM Disclosure.

Can anyone guide me which margin to put in, or if there needs to be a disclaimer that the margin shown is a representative margin and the margins may range from XXX to YYY?

Does anyone have a similar product?
Thank you.
Integrity. With it, nothing else matters. Without it, nothing else matters.