We too, have always taken the safe approach, but was challenged by the CEO as a result of it being identified as an exception. He contacted our primary regulatory who agreed with his approach. So, going forward we will not treat as rescindable. Unfortunately, 5 different examiners can interpret the regulation, and have different interpretations. Geez….
Thank you Rcooper, for your time and effort on this! It didn’t even occur to me to refer to the language in THE LAW. I’m thankful to have excellent resources and support from this group! 🙂