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#1700803 - 05/17/12 07:34 PM Interest Rate - Discretionary/Based on Index
Kelsey D Offline
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Joined: Aug 2006
Posts: 516
On a TIS disclosure, can an interest rate be both discretionary and tied to an index? The disclosure states that the margin is 100 basis points above OR below the index, so even though it's tied to an index, it's still the bank's discretion as to what the specific rate will be. Should we just say it's discretionary and omit the index, or can we state both?
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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#1700825 - 05/17/12 07:54 PM Re: Interest Rate - Discretionary/Based on Index Kelsey D
Milby Offline
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Joined: Apr 2007
Posts: 953
Why would you do both? If it is variable/discretionary, just say that. Being tied to an index is fine right now becuase the index is so low. However, when (if) it goes up you'll be locked into paying a high rate and can't control your own rates. Stating both seems way to cumbersome.

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