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#2153506 - 11/14/17 06:59 PM Construction Loan Advertisement
Antilles Offline
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Antilles
Joined: Jan 2007
Posts: 227
Southern US
Is "Construction times up to 12 months" considered a triggering term under TILA when advertising construction loans?
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#2153517 - 11/14/17 07:24 PM Re: Construction Loan Advertisement Antilles
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
Depending on the context, maybe. As a stand-alone statement, however, you are discussing hammers and nails, not financing. Reg. Z applies only to statements about the financing.
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#2153523 - 11/14/17 07:29 PM Re: Construction Loan Advertisement Antilles
Antilles Offline
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Antilles
Joined: Jan 2007
Posts: 227
Southern US
In the context of spelling out what we offer to builders. Not an actual loan product.
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#2153580 - 11/15/17 07:40 AM Re: Construction Loan Advertisement Antilles
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
If builders are the target of your ad, then Reg. Z doesn't apply.
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#2155003 - 11/28/17 02:30 PM Re: Construction Loan Advertisement Richard Insley
Rocky P Offline
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Joined: Jun 2003
Posts: 7,658
Florida
1026.2(a)2 OSC as Richard said - it's under the definition section.

ii. The term does not include:

A. Direct personal contacts, such as follow-up letters, cost estimates for individual consumers, or oral or written communication relating to the negotiation of a specific transaction.

B. Informational material, for example, interest-rate and loan-term memos, distributed only to business entities.

C. Notices required by Federal or state law, if the law mandates that specific information be displayed and only the information so mandated is included in the notice.

etc....
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