An adjustable rate mortgage (ARM) is quoted as a 3.5%, 5/1 ARM with a 30 day rate lock. Further details indicate the loan would have adjustment "caps of 3/1/5". Which of the following statements is true?

a. In the lifetime of the loan, the rate should never exceed 8.5%

b. This loan is describing a negative amortization structure

c. The mortgage rate is adjustable every 3 years with a floor of 1% and ceiling of 5%

d. This is a variable rate loan that can adjust to no more than 4.5% at the end of year 5.