2. You are only limited on the lifetime cap by your states usury laws. If management doesn't choose a cap less than state usury limit, disclose the state usury limit as the cap.
Just make sure you follow the actual disclosure rules:
8. Manner of stating the maximum interest rate. The maximum interest rate must be stated in the credit contract either as a specific amount or in any other manner that would allow the consumer to easily ascertain, at the time of entering into the obligation, what the rate ceiling will be over the term of the obligation.
i. For example, the following statements would be sufficiently specific:
D. The maximum interest rate will not exceed X%, or the state usury ceiling, whichever is less.
ii. The following statements would not comply with this section:
C. The interest rate will not exceed the state usury ceiling which is currently X%.