We want to hang a banner inside our bank lobbies advertising HELOCs and instead of quoting a specific APR and all those other disclosures, my marketing guy wants to know if we can instead say, "rates as low as prime" and avoid all the other disclosures. The banner does say to ask a CSR for details. Will this be in compliance with Reg Z?

The Official Staff Interpretations to 226.16 (see below) are clear in that if the consumer can "figure out" the rate, as they could from prime, the additional disclosures are required. Tell the officer that they do not get a free pass on this one.

Section 226.16--Advertising
3. Implicit terms. Section 226.16(b) applies even if the triggering term is not stated explicitly, but may be readily determined from the advertisement.