If you have an ad for a construction loan that says "Interest only monthly payaments during construction period", would that not trigger some additional disclosures, like the amount of the interest and the balloon that would occur if the ad also states that the construction loans are 6-12 months? I think the 6-12 month terms disclosed on the ad would also be a trigger term that would require additional disclosures (like the APR and amount of payments/balloon). Am I wrong? It's not our advertisement - it's another bank's flyer but our construction department wants to do one just like it and doesn't know why I would have a problem with it.

"6 - 12 month term" is a trigger term but I/O payments is not. If you have friendly relations with the competitor, make a courtesy call to your peer. Say that your lenders want to file a formal complaint with your competitor's regulator if you won't let them do the same thing. If you don't have friendly relations, skip the courtesy call and go directly to the formal complaint.

I used to help my marketing director do this when competitors got over the line. He loved to play hardball. I drafted the letters for his signature & it always put a smile on his face to rat out the competitors. From that point on, the relationship between the marketing and compliance depts. improved considerably.