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#1619782 - 10/25/11 06:34 PM 0% interest loans
HubbaBubba Offline
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Joined: Sep 2002
Posts: 311
This may be a "no-brainer" but need input:

If we advertise 0% christmas loans to be repaid back in 12 months, with a minimum loan amt of $200 and a max of $1000, do we need any other disclosures on the ad?

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Lending Compliance
#1619788 - 10/25/11 06:39 PM Re: 0% interest loans HubbaBubba
straw Offline
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straw
Joined: Nov 2002
Posts: 9,121
check Reg Z 226.24. Term is a trigger, requiring those disclosures. You'll want to state "on approved credit" as well and any other qualifiers for UDAP.

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#1619809 - 10/25/11 06:54 PM Re: 0% interest loans straw
HubbaBubba Offline
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Posts: 311
Thanks, Straw.

Now here's another twist - if the ad is being paid for by a city's Chamber of Commerce, does Reg Z still apply?

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#1619811 - 10/25/11 06:55 PM Re: 0% interest loans straw
Cornfed Turtle Offline
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Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
Speaking from experience here....make sure you take out the "minimum finance charge of $xx.xx" from your Promissory Note.

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#1619859 - 10/25/11 07:39 PM Re: 0% interest loans HubbaBubba
HubbaBubba Offline
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Joined: Sep 2002
Posts: 311
Originally Posted By: HubbaBubba
Thanks, Straw.

Now here's another twist - if the ad is being paid for by a city's Chamber of Commerce, does Reg Z still apply?


Does anyone have any input for me????

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#1619876 - 10/25/11 07:49 PM Re: 0% interest loans HubbaBubba
RR Joker Offline
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The Swamp
Who pays for an ad would have no bearing on Reg Z disclosure requirements.
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My opinion only. Not legal advice.

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#1619886 - 10/25/11 08:02 PM Re: 0% interest loans HubbaBubba
swiggles Offline
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swiggles
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Originally Posted By: HubbaBubba
Thanks, Straw.

Now here's another twist - if the ad is being paid for by a city's Chamber of Commerce, does Reg Z still apply?
How nice of the your chamber. Are you the only bank in town?
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The more you sweat in training, the less you bleed in battle.......

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#1619891 - 10/25/11 08:08 PM Re: 0% interest loans swiggles
HubbaBubba Offline
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Joined: Sep 2002
Posts: 311
Yes - they are also promoting community bucks - that is how the loan is disbursed (thus, the free ad)

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