We are launching a HELOC promotion with a fixed introductory rate for one year. After the first year, the loan will revert to standard pricing. In our advertising, the introductory rate/APR is very prominent, with an asterisk to the details outlining features of both the introductory rate and standard pricing (effective date, margin, index, etc.). Is it acceptable to have the initial introductory rate/APR more prominent in the ad and describe the standard pricing in the details below?

Mel,

I think no based upon the information below,

1026.16

(2) Discounted and premium rates. If an advertisement states an initial annual percentage rate that is not based on the index and margin used to make later rate adjustments in a variable-rate plan, the advertisement also shall state with equal prominence and in close proximity to the initial rate:

(i) The period of time such initial rate will be in effect; and

(ii) A reasonably current annual percentage rate that would have been in effect using the index and margin.

For this same promotion, is a sample payment only required for the variable rate portion or do both rate options (fixed promotional and remaining term variable) need a sample payment in the fine print?

Bump