Has anyone updated their bank's web site yet to comply with the Reg. Z advertising rule changes that are effective 10/1/09? If so, are you willing to post a link to your bank's web site or send me a PM with a link?

I am reading the requirements to indicate that if we have an ARM product secured by a dwelling where the initial rate is discounted or at a premium (not based on index and margin used for later rate adjustments), then we must show a payment example based on payments at the discounted or premium rate and payments based on the fully indexed rate. If periodic caps would prevent the initial rate from going up (discounted product) or down (premium product) to the fully indexed rate, do we have to show payments based on the capped interest rate like when you do a payment schedule on a TIL followed by the remaining payments based on the fully indexed rate?

Your advertising disclosures should work exactly like the transaction TIL payment schedule and APR.

Thank you.

Is listing the APR in an advertisement (newspaper) a trigger term. What about listing the annual maintenance fee?
If they are, what else would I need to add to the ad.
I have been reading the reg all morning but it is not making any sense to me. I know I know this but.....compliance overload

I guess this also applies to the rate sheet on the web?

Yes. The Fed's position has always been that full payment schedules should be included in ads--it just wasn't enforced aggressively. Maybe if the regulators had done so, more borrowers would have paid attention to looming payment increase disasters in time to avoid them.

What impact do you see for digital signage within the branch for rates? We generally see two approaches: 1) Rates beginning at xxx or 2) a full rate board with disclaimer area. How much information is too much? For content (size, amount, etc.) we normally suggest that they be treated like a billboard - few words, easy to read from a distance. Rates pose a new set of issues. Have you seen guidelines that are specific to digital signage?

Probably a stupid question . . . but then at this point in this never ending sea of regulation changes, I don't really care.

If we charge a higher rate of interest than the normal/best rate, due to a borrower's credit score and the loan to value, do we have to include every possibility of that increased rate for all loan products on a rate cheat that sits in our lobby? Or is it enough to say higher rates may be charged due to your credit score and LTV. Thanks

Of course you can charge higher rates for higher risk customers. Your rate sheet is not a firm offer. There is no way to list every possible rate. You also don't need "higher rates may be charged due to your credit score."

I don't recommend handing our rate sheets to customers anyway.

I participated in BOLs Reg Z New Advertising Rules on 8/3/09. The published Q&As, question 23 "Will you be providing an ad review checklist of any kind? Answer "That sounds like a great idea. We'll see what we cn come up with and post it on Bankers' Tools prior to the October 1, 2009 effective date for the changes."

I've looked at the checklist in Bankers Tools and they are all dated 2003. Any idea if this will be updated and if so when?

Thanks.

I am trying to wrap my head around this. Are more banks just pulling rate sheets off their web sites. Anyone want to share a web site where rates are posted compliantly within the new Regs?

Here's a rate page that provides what would appear to be complete payment schedules. I didn't check the accuracy of the payment amounts or the APRs, but at least this bank understands what must be included.

I looked at a couple dozen banks before finding this one. All of them were wrong. Some contained trigger terms but no payment schedules. Others provided initial payments, but not the "steps" that will occur in premium and teaser priced loans.

Thanks Richard, as always, for your help.

Did you ever get a response to your question about APR's in newspaper ads and what additionally is required Rivergirl? If so would you share?

I am also interested in what may happen to newspaper ads such as BankRate where there is a chart that is filled in with each bank's rate.

As a side note, for now we have removed our HE lines of credit with a lower initial rate from our web site until further notice. We still have the product, we just don't have it listed as a "special" rate right now.

If you don't pay for it and have no say in what the paper chooses to compile and print, it's news - not an advertisement.

If you have an ad for credit secured by a dwelling and it includes triggering terms that require disclosure of the terms of repayment required by section 226.24(d)(2) of Regulation Z it seems you must also make the payment disclosures required by section 226.24(f)(3). How do these differ? Can anyone give me an example? Thanks.

Unfortunately we do pay to be in the chart, but we have no control over the chart other than to supply our rates.

Bump. Is anyone on BOL working on this? Would be of GREAT Value.

Thank you for giving us that example bank, Richard! That helped a ton! I have a question - on ours, you don't get that popup information on the TIL unless you click on the actual payment amount - do you think that will satisfy an examiner? I'm concerned with the language that this needs to be disclosed in a clear and conspicuous manner - it's clear if you know to click on the payment amount but nothing tells the consumer to click there for additional payment info.

Hi,

Quick question...I just want to verufy the Reg Z advertising changes were in effect as of 10/1/09 and the effective date was not postponed. Just want to make sure I did not miss any change to the effective date.

Please let me know. Thanks!

The rule was effective 10/1/09 and was not postponed. However, additional changes were made to the advertising rules for open end credit. Some changes were effective 2/22/10 and some changes are effective 7/1/10. Here's a link to BOL's Read A Reg section for section 226.16 of Reg. Z. You should also look at the corresponding secton of the official staff commentary.

http://www.bankersonline.com/regs/226/226-16.html

thanks!

Richard,

That link is dead. Do you know if this bank is the same?

http://fairfieldcountybank.mortgagewebcenter.com/Default.asp?bhcp=1