Considering a piece to highlight financing on OREO property. It will show the % down, max DTI, term, interest rate, for several credit score ranges. For example, the rate for 675-699 score might be 4.50% with 5% down, 35% DTI, and 15 yr. term. The rate for the same score range, but with a 30 yr. term might be 4.75%.

How would we disclose payments on this piece? This piece would be intended for brokers, not applicants. Thanks.

Using your proposed selling price and your down payment and rate/term info, you willl be able to disclose your APR as well as the payment schedule.

If this is marketing information intended to be given to brokers/Realtors to give the specifics of the property then the adverstising rules do not apply. See the Commentary to 226.2(a)(2)(ii).

Thanks for your comments!

Dan is absolutely correct. I have however, run into LO's who take these pieces and use them as general advertising. (don't get me started on the LO's) Because of the risk of "trigger happy" LO's we require ALL advertisements to meet the reg requirements. The only exception is the standardized rate sheets. Hopefully you don't have this problem and can go with the simpler advice from Dan.

If we do show to potential individual customers, would I need to disclose the payment example and apr for each of the credit score ranges and terms (15 yr term based on each score range and 30 yr term based on each score range) OR each score range based on one of the terms OR terms only based on one score range OR will one example cover it all? Thanks.

What do you think on this please?

If the add contains triggeering terms you would have to show a representative example for each term advertised.

So if I have 4 credit score ranges for 15 yr. term and amort. and the same 4 ranges for 30 yr. term, I would have to show 8 payments and 8 APRs. Right??
Thanks

If you are making this usable as a general advertisement, yes you would need the disclosures for all 8 scenarios. We have done this in the past in table formats that can look and work pretty well.