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#1763242 - 12/03/12 02:19 PM Fixed Rate Mortgages
terpsfan Offline
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Joined: Feb 2007
Posts: 1,980
Would stating that we offer fixed rate mortgages require any additional disclosures under 1026.24 i(1) Misleading advertising of fixed rates and payments? We offer truely fixed rate amortizing loans but we also offer adjustable rate loans and balloons.

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#1763777 - 12/04/12 07:26 PM Re: Fixed Rate Mortgages terpsfan
terpsfan Offline
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Joined: Feb 2007
Posts: 1,980
bump

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#1764073 - 12/05/12 05:03 PM Re: Fixed Rate Mortgages terpsfan
terpsfan Offline
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Joined: Feb 2007
Posts: 1,980
Can we advertise that we offer fixed rate mortgages without disclosing all the other variable loan terms we also offer?

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#1764179 - 12/05/12 07:45 PM Re: Fixed Rate Mortgages terpsfan
Reads Regs Offline
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Joined: Nov 2004
Posts: 2,294
I think you can but why not mention that they contact you for information about other available loan programs.
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.

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#1764436 - 12/06/12 02:20 PM Re: Fixed Rate Mortgages terpsfan
terpsfan Offline
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Joined: Feb 2007
Posts: 1,980
It is just a general list of products and it says we offer fixed and variable rate mortgages but we were told this violated 1026.24i(1) since we also offer balloon loans and 12 month bridge and construction loans.
Last edited by terpsfan; 12/06/12 02:22 PM.
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#1764500 - 12/06/12 03:04 PM Re: Fixed Rate Mortgages terpsfan
terpsfan Offline
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Joined: Feb 2007
Posts: 1,980
Pretty much they are saying it is wrong if we say we offer fixed rate mortgages unless all of our loans are truly fixed.

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#1764515 - 12/06/12 03:14 PM Re: Fixed Rate Mortgages terpsfan
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,663
Galveston, TX
First: who is "they"?

Second: You are only advertising your Fixed-Rate Mortgages and your Variable-Rate Mortgages. There is abosolutely no requirement to advertise all of your products that may be available. You offer what you say, there is nothing misleading about that.

Whoever "they" is, "they" are way off base.

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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1764523 - 12/06/12 03:20 PM Re: Fixed Rate Mortgages terpsfan
terpsfan Offline
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Joined: Feb 2007
Posts: 1,980
They are auditors not examiners and I completely disagreed with the finding and that is why I wanted some input from this board. Thanks for your help and I am glad that I am not the only one thinking they are way off base.

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#1764542 - 12/06/12 03:39 PM Re: Fixed Rate Mortgages terpsfan
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,663
Galveston, TX
Kick this up to their head office and find some new auditors if they continue to push this.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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