When speaking to a customer, the APR should be provided. If the other guy isn't doing that, I'd nudge them in the right direction. If they are gaining a competitive advantage through willful blindness, I'd give them a shove.
Look beyond the advertising requirements though, when speaking with other lenders, and look at the definition of "advertisement". See what fits, and what doesn't.
§226.2 Definitions and rules of construction.
ii. The term does not include:
A. Direct personal contacts, such as follow-up letters, cost estimates for individual consumers, or oral or written
communication relating to the negotiation of a specific transaction.
B. Informational material, for example, interest rate and loan term memos, distributed only to business entities.
When addressing customers, you may also provide full disclosure and do the lemons to lemonade trick. "Mrs. Customer, the APR on this request would be X.XX%. That is based on an interest rate of X.XX%, points and fees of... Hopefully this answers all the questions you have now. There is nothing hidden here. I'm sure the other lenders have provided you with the same information."
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell