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October 24
How to Audit Advertising - Compliance Issues Here, There, Everywhere!;
Patricia Cashman

October 29
Documenting an Applicant's Intent to be a Joint Applicant;
David Dickinson

November 4
Issues with Deceased Customers;
Mary Beth Guard and John Burnett

November 5
Vault Burglaries, Floods, Fires & Other Disasters;
Dave McGuinn

November 6
MLO v LO - Who Has to Do What?;
Jack Holzknecht and Mary Beth Guard

November 13
Domestic Violence & Workplace Violence: There Is A Link;
Shelly Collins and Dana Turner



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

Registered: 06/11/02
Posts: 220
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: 50412
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 Offline
100 Club

Registered: 06/11/02
Posts: 220
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: 7579
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: 50412
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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