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#1099678 - 12/18/08 06:34 PM Advertising for Loan Products
SuperBanker Offline
100 Club
Joined: Nov 2006
Posts: 243
I know that you have to disclose all rates as annual percentage rate on any advertising for loans secured by a dwelling. I also know that you can state simple interest rates as long as they are not larger than the APR. However, do you have to disclose what is required in order to receive that simple interest rate and APR or can you make a generic statement such as, "I may just be the right time for you to refinance or buy a new home. Come by and talk with us today and see if we can lower your monthly payments." I think we need to be more descriptive in what the customer has to do in order to receive the rate on the advertisement. Any thoughts?

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#1099707 - 12/18/08 06:59 PM Re: Advertising for Loan Products SuperBanker
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
You should review section 226.24 (assuming it's closed-end) and the commentary to that section. That way, no one assumes you do or don't have content that may fall under other requirements for disclosure.

If you stay really generic, such as what you have in quotes...and don't quote rates...you don't have any requirements but your doghouse logo.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#1099732 - 12/18/08 07:18 PM Re: Advertising for Loan Products RR Joker
SuperBanker Offline
100 Club
Joined: Nov 2006
Posts: 243
What if we do post an annual percentage rate? Would we have to go into detail about the requirements to be able to receive that rate?

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#1099798 - 12/18/08 08:09 PM Re: Advertising for Loan Products SuperBanker
David Dickinson Online
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David Dickinson
Joined: Nov 2000
Posts: 18,763
Central City, NE
The APR triggers more info IF it is an open-end product. If it is closed-end, it doesn't trigger anything. Ask Joker suggested, review §226.24 and §226.16 (for open-end loans).
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David Dickinson
http://www.bankerscompliance.com

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