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#1004605 - 07/25/08 02:08 PM Reverse Mortgage Advertising
aliasg Offline
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Joined: Jul 2007
Posts: 148
MD
Don't advertisements for reverse mortgages that indicate the 62 years of age requirement discriminate based on age? Are there specific advertising requirements for reverse mortgages?

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#1005041 - 07/25/08 05:11 PM Re: Reverse Mortgage Advertising aliasg
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
Refer to Reg. B's Commentary to 202.6(b)(1)(4).

We don't do reverse mortgages but they are subject to Reg Z and its provisions.
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#1005068 - 07/25/08 05:22 PM Re: Reverse Mortgage Advertising Dan Persfull
#Just Jay Offline
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#Just Jay
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
4. CONSIDERATION OF AGE IN A REVERSE MORTGAGE. A reverse mortgage is a home-secured loan in which the borrower receives payments from the creditor, and does not become obligated to repay these amounts (other than in the case of default) until the borrower dies, moves permanently from the home, or transfers title to the home, or upon a specified maturity date. Disbursements to the borrower under a reverse mortgage typically are determined by considering the value of the borrower's home, the current interest rate, and the borrower's life expectancy. A reverse mortgage program that requires borrowers to be age 62 or older is permissible under §202.6(b)(2)(iv). In addition, under §202.6(b)(2)(iii), a creditor may consider a borrower's age to evaluate a pertinent element of creditworthiness, such as the amount of the credit or monthly payments that the borrower will receive, or the estimated repayment date.
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#1005622 - 07/26/08 11:37 AM Re: Reverse Mortgage Advertising aliasg
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
Reg B allows you to treat those who are "elderly" (age 62 by definition) more favorably than others. Most reverse mortgage programs become available at a minimum age of 62, but not all. If you are offering one that has a lower eligibility requirement (60, for example), you have a problem. Rejecting a 59 year-old applicant due to age would be discrimination if 60 year-olds can qualify.
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