The new Regulation Z rules that take effect on October 1 will require us to display with equal prominence any rate that could apply during the term of the loan.

If we advertise a reduced rate for auto payment and then that auto payment discontinues and we bump the rate up, will we need to advertise that rate in the ad as well?

Also, if we have multiple rates for one product (for example HE Closed End loan) with a rate for auto payment from an account w/ us, a rate for auto-payment from an account at another FI, and then a rate for no auto deduct, would we now need to disclose all rates in equal prominence in the ad?

The OSC to new section 226.24(f)(closed end credit ads secured by a dwelling) states the following about preferred rate loans.

" ii. Preferred-rate loans. Some loans contain a preferred-rate provision, where the rate will increase upon the occurrence of some event, such as the consumer-employee leaving the creditor's employ or the consumer closing an existing deposit account with the creditor or the consumer revoking an election to make automated payments. A creditor need not assume that the preferred-rate provision, by itself, means that more than one simple annual rate of interest will apply to the loan under Sec. 226.24(f)(2) and the payments that would apply upon occurrence of the event that triggers the rate increase need not be disclosed as a separate payments under Sec. 226.24(f)(3)(i)(A)."