Yes they are protected. The variable rate exception only applies if the index is not under the creditor's control. Official Staff Comment 2.ii. to Section 1026.55(b)(2) indicates that if there is a floor rate, the index is treated as being under the creditor's control. Thus the variable rate exception is not applicable. The advance notice exception (1026.55(b)(3)) requires that you protect the existing balances.
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