We have some older HELOC's with floors of 3%. If the customer requests a subordination agreement from us due to refinancing their 1st mtge, can we take this opportunity to raise the floor as a condition of us signing the Subordination Agreement?

We had HELOCs with no floors and took subordination requests as an opportunity to reprice them. If the customer agreed, we did modification and change in terms. If they did not agree to the new floor, we looked at whether or not the subordination was still in the bank's best interest (did the customer really benefit from the transaction, thereby putting us in a better position). If so, we would still go ahead with the subordination.

Thanks, MyScamper. Did you do any kind of re-disclosures at the new rate??

Modification agreement that spelled out new terms.