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April 16
Handling ACH Origination Exception Issues
Shelly Simpson

April 17
Fair Lending - Internal Monitoring
Patricia Cashman

April 22
A Banker's Guide to Virtual Currency
Andrew Beal

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



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#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: 48485
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 Online
Power Poster

Registered: 10/26/00
Posts: 7332
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: 48485
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.
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The opinions expressed are my own, take them or leave them.

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