I am working on a general policy statement. It is actually pretty easy for us since we are not a mortgage lender. We do Home Equity loans mainly to accomodate personal needs of business customers. However, anyone can apply, we just don't advertise them. Our pricing is nowhere near in danger of triggering coverage, our fees are modest, plus we are conservative in LTV and credit qualification.
So basically, our procedure stays the same, and our policy will reflect that we will observe the indexes and make sure our pricing will not trigger coverage.
Regulations are a poor substitute for ethics.