If we price HELOCs based on the applicant's credit score and loan to value ratio, so some borrowers get a lower rate than other borrowers, can we disclose the lower rate in our advertisement, or do we need to disclose both rates? Do we also need to specify the criteria for receiving the lower rate?
If we have a rate sheet that we give to real estate agents and our loan originators, but we know the true use will be for them to hand it to consumers or post it where consumers can readily access it, wouldn't we need to have the APR on it?
We often have lobby posters advertising products, services, benefits like trips on a discounted price and others things on display so staff can answer questions on these and to promote these items. Do they require the general FDIC advertising statement>
We include the Equal Housing Lender logo in all our home loan ads. Are we also required to include the “Equal Opportunity Lender” logo?
I read about HMDA data problems with Freedom Mortgage. What was the real issue?
How does fair lending impact commercial loans, which is not “consumer protection” controlled?
What is the “one-click away” rule for electronic advertisements?
Should we handle fair banking like fair lending?
Is following the standard Regs, B, Z, DD and fair housing going to ensure advertising compliance?
What are some recommended elements of a fair banking program?