Hi Charles
As a rule I only operate the penalty for Devotee's improvising hitherto unheard of feats in the -5 to -10 range, as I feel that Devotee's are more adept, and I also feel they deserve the bonus.
Initiates I like to pin back, so thats why I would be hesitant to use your method, although in reality the penalties are so prohibitive as to make unlikely anyway IMO. I think page 118 of HQ relating to Initiate use of Affinities excludes what you propose, but if it works for your game, great! ;^D
Regards
Rob
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