To your point, what bothers me is, that we execute rate lock-ins our secondary mortgage department through a signed agreement with the borrower. Then, when a lock-in needs to be extended, it might be done between us and the investor without an agreement with the borrower. It seems another agreement with the borrower though isn’t necessary on whether to use later extension date, as it says “if a rate is reset after a lock-in agreement is executed (for example, because the borrower exercises a float-down option or the agreement expires), then the relevant date is the date the financial institution exercises discretion in setting the rate for the final time before final action is taken. The same rule applies when a rate-lock agreement is extended and the rate is reset at the same rate, regardless of whether market rates have increased, decreased, or remained the same since the initial rate was set."
What do you think? Should we use the later extension date since it was our discretion whether to extend the rate or not?