Question: When presenting to a group of Realtors - does your brochure that lists the types of mortgages offered have to disclose APR if you are not quoting a rate? Are you able to give Realtors a rate sheet without APR's listed as long as Reg Z info is at the bottom?
Answer by Dan Persfull: The advertising rules do not apply on business to business communications. However, your dilemma is whether the Realtors will provide this rate sheet to their clients.
Answer by Richard Insley: No boilerplate can substitute for a proper advertising disclosure. Dan offers sound advice about B2B communications. If you're reasonably sure the rate sheets with your bank's name on them are not redistributed to consumers, then these sheets do not meet the Reg. Z definition of an "advertisement." Otherwise, treat them as covered by Section 226.24.
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