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#1393477 - 05/19/10 05:38 PM Trigger Terms - advertising compliance
mortgage banker Offline
New Poster
Joined: Sep 2009
Posts: 7
Oregon, USA
We are currently running a webpage e-mail add that contains a mortgage calculator. The data in the calculator is manipulated and input by the user (rate, loan amount, term) and will then calculate a payment. To remain compliant with Reg Z are we required to include APR, downpayment, and terms of repayment? Or since we are not providing the rate, loan amount information, and term (input by user) are we exempt from this requirement? Should we include some other type of disclaimer? (terms, rate, etc not deemed reliable)

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#1394923 - 05/21/10 10:00 PM Re: Trigger Terms - advertising compliance mortgage banker
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,056
Toano, VA
If the calculator pre-fills with a particular deal, you should probably treat it as an ad. On the other hand, if it's a simple payment calculator that's served blank & has no capability to import terms & conditions of deals you offer, it's not an ad.
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#1395210 - 05/24/10 06:16 PM Re: Trigger Terms - advertising compliance Richard Insley
mortgage banker Offline
New Poster
Joined: Sep 2009
Posts: 7
Oregon, USA
Thank you for your feedback. It is a calculator that is all manual input from the viewer. There is no autofilled information, therefore the borrower could type in rates and terms that don't technically exist.

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#1400121 - 06/05/10 11:38 AM Re: Trigger Terms - advertising compliance mortgage banker
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,056
Toano, VA
Review the rest of the page to see if other requirements are triggered, but the blank calculator is not an ad. Be sure the calculations are accurate, however. I've heard regulators say that they sometimes check these things, find the numbers are off, and handle the problem under UDAP.
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