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#2087034 - 07/07/16 05:31 PM Marketing Historic Example
M Cockrell Offline
Diamond Poster
M Cockrell
Joined: Jan 2003
Posts: 1,048
Dallas, TX
Does advertising, which includes historical examples (e.g. RE Loan for $$$,000 on a # year term/amortized for # years with a LTV at ##%), trigger any further disclosure?

No rates/APRs disclosed, just types of loans, term & amo lengths, and LTVs.

Would it make any difference if some had an interest only period?
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Lending Compliance
#2087047 - 07/07/16 06:02 PM Re: Marketing Historic Example M Cockrell
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
(e.g. RE Loan for $$$,000 on a # year term/amortized for # years

1026.24

(d) Advertisement of terms that require additional disclosures. (1) Triggering terms. If any of the following terms is set forth in an advertisement, the advertisement shall meet the requirements of paragraph (d)(2) of this section:

(i) The amount or percentage of any downpayment.

(ii) The number of payments or period of repayment.

(iii) The amount of any payment.

(iv) The amount of any finance charge.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2087058 - 07/07/16 07:03 PM Re: Marketing Historic Example Dan Persfull
M Cockrell Offline
Diamond Poster
M Cockrell
Joined: Jan 2003
Posts: 1,048
Dallas, TX
But if all the historical examples advertised were for BUSINESS related credit only, that would remove the Reg Z requirements, correct? (My bad for not stating that in the original post.)
_________________________
"Remember no man is a failure who has friends." - Clarence (the Angel) Oddbody - It's a Wonderful Life

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#2087060 - 07/07/16 07:06 PM Re: Marketing Historic Example M Cockrell
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
If the loans are business purpose, the Reg Z advertising rules do not apply.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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