I know we can't advertise "lowest rates" without being able to substaniate such a claim. Marketing wants to use the following phrase, "Home of low rates and hassle free closings" for a print mortgage loan ad. Is this ok? Both claims make me a bit nervous.

For me, I feel your "nervousness" especially in the light of UDAAP. I mean what's hassle free for me is not always hassle free for you. Its a generic euphemism and generally is regarded as such.

To me having the phrase "low rates" is more the sticky wicket... Low rates relative to what? Rates at 6% may be low for your bank but not low for the banking world...

In this instance I would rather see a statement "rates as low as X% and then all the disclosure print. I know it seems to complicate an easy situation but with broad and uneven application of UDAAP I would rather fall back to a position I know I can defend than a position that leaves me exposed.

Those are just my thoughts though. Somebody else may offer better suggestions.

Cheers!