In 90 days you might find yourself 150 or 200 basis points underwater - I would be asking what difference does it make if it is day 89 or day 91. Also, who's fault is it that it is taking that long to close? There are a lot of considerations when determining the fair lending impacts of such a policy. Not saying what you propose is undoable, but you will need some rock solid controls in place.
What I do find interesting is watching bankers starting to panic that have never been in a fast-rising rate environment. In 1980 for example - here is just a little snippet of the prime rate history. We might get a 25 basis point move in a month right now - back then the Prime Rate would change about weekly.
March 4, 1980 - 17.25
March 7, 1980 -17.75
March 14, 1980 -18.50
March 19, 1980 -19.00
March 28, 1980- 19.50
April 2, 1980 - 20.00
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