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#176675 - 04/05/04 02:35 PM Advertising rates inside the bank lobby?
jules13 Offline
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Joined: Apr 2003
Posts: 23
We have a rate board posted in the entrance of each branch office of our bank. The board includes the following: Bank Name, term of loan(15 years), the rate, FDIC logo, Equal Housing Lender logo, and two statements "Rates subject to change daily." and "All applicants are subject to credit approval."

I am the Compliance Officer and was given the opportunity, initially, to review the contents of this board, and I stated that APR had to be on the board (as conspicuous as the rate) as well as a payment amount based on a $100,000 loan example. (i.e. Rates above based on upon $100,000 loan example
30 year(360 Payments) Principal and Interest Payment = $ 559.97
15 year(180 Payments) Principal and Interest Payment = $ 771.40)

Management decided they did not want to list these items. Can someone tell me if this does not have to be on the board because it is located inside the Bank?

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Lending Compliance
#176676 - 04/05/04 03:48 PM Re: Advertising rates inside the bank lobby?
Beagles22 Offline
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Joined: Jan 2004
Posts: 3,626
State of confusion
Any ad has to have that information on it, and since this board is up in order to convince people to get a loan, or to obtain that service from your bank...I think definately. Just tell the management that the board is the equivalent of an advertisement, point out that flyers are in the bank as well, but still requires all ad info in order to comply with the regs.
Going to church doesn't make you a christian any more that standing in your garage makes you a car.

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#176677 - 04/06/04 02:09 PM Re: Advertising rates inside the bank lobby?
Andy_Z Offline
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Joined: Oct 2000
Posts: 27,748
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"Z" doesn't distinguish inside-outside-connected to the building like some others may. Triggering terms decide this.

If the trigger terms are there, you must expand and comply. So either add to it, or remove the trigger terms. This is a key reason many banks have deposit rates on boards, but not loan rates.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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