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#20054 - 06/07/02 07:35 PM Rates on telephone response machines
BKB Offline
100 Club
BKB
Joined: May 2002
Posts: 120
Midwest
Is there an out for full disclosure of credit advertisment triggered terms when giving an APR or otehr triggering term on a telephone response machine, which is available to the general public? Assume that the bank discloses triggering terms for both open end and closed end products.
I can't seem to find an exclusion for omitting triggered terms just because it is on a telephone response machine. In all prior lives, the banks never chose to put rates on this medium so I never worried about it.
Thanks!

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Lending Compliance
#20055 - 06/07/02 07:42 PM Re: Rates on telephone response machines
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Sorry, but TIL offers no exemptions for any type of media. TISA does, but that is for APY's. If you trigger on the telephone response machine, you trigger everything.
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David Dickinson
http://www.bankerscompliance.com

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#20056 - 06/07/02 09:16 PM Re: Rates on telephone response machines
Way Out West Offline
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Way Out West
Joined: Jun 2001
Posts: 246
San Francisco
David is correct -- telephone response systems are advertising under Reg Z. But remember, for what it's worth, stating the APR by itself, or the simple interest rate in conjunction with the APR, is not a triggering term for fixed-rate closed-end credit at least. So it is possible to put limited rate info out there with a minimum of other confusing legalese.
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The opinions expressed are mine and not those of my employer

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