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.