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)

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.

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.

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.