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In Response To:
Thread Starter: rlcarey
Title: Re: HELOC Floors

"While your earlier statement about a new plan makes sense, I don't see the harm to the consumer if we disclose a floor of 6% but in some cases it actually ends up being 5%. "

You are going to lose business with this approach. Also, I don't understand why the decision is only made at closing? What are the criterion. This tells me that you might not want to "suppose" there are no fair lending risks.