Re: ARM Question


Assuming you have disclosed everything properly, then I don’t think you have a compliance issue.

You should look at it from the standpoint of UDAP and see if you have any concerns. UDAP is so open to interpretation, so I can’t give you definitive answer as it relates to UDAP, but since it kind of seems misleading, as most rate are either offered at a discount or at rate + margin, I could possibly see it leading there.