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April 24
BSA/AML Compliance: Writing the SAR Narrative
Ken Golliher

April 29
HSA Basics
Whitney Johnson

April 29
Required Training for Loan Originators
Mary Beth Guard and Jack Holzknecht

May 13
Overdraft Practices in Today's Regulatory Environment
John Burnett

May 14
Reg E Claims - Allocating Liability Correctly
Andy Zavoina

May 15
Managing Electronic Information - From A to Zettabyte
Fred Menge



Topic Options
#1662728 - 02/09/12 12:19 PM ARM advertisement
low profile Online
100 Club

Registered: 06/11/02
Posts: 202
Loc: Pennsylvania
Our bank is contemplating offering a mortgage with a 30 year term which will adjust once at the beginning of the 16th year. To promote this product our ad will refer to the "30/15 Mortgage." This verbage is exact and no other description of this mortgage product will be indicated.

What advertising disclosure requirements would I need to provide?
_________________________
Living is easy with eyes closed, misunderstanding all you see.

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Marketing
#1662752 - 02/09/12 12:55 PM Re: ARM advertisement [Re: low profile]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 48565
Loc: Galveston, TX
""30/15 Mortgage." This verbage is exact"

Exact? It means nothing to me.
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The opinions expressed are my own, take them or leave them.

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#1662855 - 02/09/12 01:42 PM Re: ARM advertisement [Re: rlcarey]
low profile Online
100 Club

Registered: 06/11/02
Posts: 202
Loc: Pennsylvania
Good. I was concerned it would be a trigger term since the term is 30 years.
_________________________
Living is easy with eyes closed, misunderstanding all you see.

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#1662857 - 02/09/12 01:43 PM Re: ARM advertisement [Re: low profile]
Richard Insley Offline
Power Poster

Registered: 10/26/00
Posts: 7348
Loc: Richmond, VA
If you indicate a 30 year term, that's a trigger.
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...gone fishing.

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#1662860 - 02/09/12 01:57 PM Re: ARM advertisement [Re: low profile]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 48565
Loc: Galveston, TX
Good? It represents the term of the loan and triggers additional disclosures. I meant that 30/15 means nothing to me regarding the type of product this might be. Unclear = read UDAAP.
_________________________
The opinions expressed are my own, take them or leave them.

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