Our marketing department is creating a generic :15 second video promoting our HELOC product. No specific rates are stated; however, they use the terms "low rates" and "no closing costs." The question has been posed regarding the rate and margin disclosure; specifically, would saying, "Variable rate based on The Wall Street Journal prime rate plus a factor" be satisfactory?

16(d) Additional Requirements for Home-Equity Plans

1. Trigger terms. Negative as well as affirmative references trigger the requirement for additional information. For example, if a creditor states no annual fee, no points, or we waive closing costs in an advertisement, additional information must be provided.

You will trigger all other specific advertising requirements, including disclosing an actual APR.

Thanks, Randy. I appreciate the guidance.