I agree (thanks to Richard Insley and David Dickenson showing me the error of my ways!) that loan terms (30 year fixed, 5/1 ARM, etc) on a website or in an advertisement are triggering terms. I had instructed our marketing department to be sure that any such references were either removed from our site, or properly disclosed. My mortgage folks are now insisting that all they need to have on our site is a "representative sample" of APRs, but that current rates and terms are not required. I am concerned that such a practice could be considered "bait and switch" advertising. They said, "SunTrust does it, so why can't we?" Yes, SunTrust does have a representative rate sample on their site, but they also have a current rate sheet (mortgage rates good for applications submitted through tomorrow).
Last edited by mbguard; 07/11/02 05:30 PM.
What do I need to do to satisfy the Advertising requirements of Reg Z in this instance? Is just a representative rate sample acceptable? Crazed mortgage people are circling their wagons and loading their weapons outide my door! Help me, please!
Being kind is more important than being important.