Posting Base/Prime Rate in Lobby
Answer by Richard Insley, BOL Guru BIO AND CONTACT INFO
Question: I thought I read somewhere that we can post the bank's Base Rate or Prime Rate in the lobby without stating it as an APR. After brushing up on Reg Z, I'm thinking I'm wrong. Here is an example of our lobby sign: XYZ Bank Base Rate 7.76% Is that okay?
Answer: If you are stating your prime rate as part of an advertisement for a particular product, then the ad must also show the APR. On the other hand, if you display your prime rate for the general information of commercial and other customers who already have accounts tied to the index, then it's not an ad and there's no need to show an APR.
Kirchman - scroll to manual page 5.22, Fair Housing Advertising for an excellent recap of agency-by-agency requirements.
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