Marketing would like to do a prescreened HELOC offer but not provide rates or line amounts. Typically, they've included rate offers, but since rates are rising, they don't want to focus on the rates. I think it's a UDAAP risk because they don't want to provide any rate details, even though since they prescreened everyone, they know what they could qualify for based on their credit, available equity, etc. Also, someone who takes them up on this offer wouldn't know what to expect. Has anyone done this? Thoughts?

Rates are one thing - but how is it a firm offer of credit if they are not offering a specific loan amount?

Plus - prescreening for HELOCs is a losing proposition. Typical prescreened offers have less than a 1% response - HELOCs even less.