I found one conversation similar to this, but the example given was a statement using an APR. If we post an invitation stating: "If you have a home loan with an interest rate greater than "x" call us today to see if we can lower your mortgage payment" are we OK since we are not advertising our rates directly?

Bump

As long as there's a real potential for lowering payments if the current loan has a rate of X%, I don't see a problem. I would have a problem if most folks who contact you with a rate greater than X% find that you can't help them unless they stretch out their amortization schedules.

Also, the implication in your invitation is that you readily make available rates of X% or lower. If you only offer such rates to folks with 6-figure incomes and credit scores over 800, I'd be concerned about UDAP of the "bait-and-switch" variety.