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#2190993 - 08/29/18 02:05 PM Mortgage Rates on Website
Bec Offline
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Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
Trying to determine if I need further disclosures if our website states rates as:

Program Name Rate APR
15 Year Fixed (conforming) 4.00% 4.08%
30 Year Fixed (conforming) 4.625% 4.71%
7 Year ARM (conforming) 4.625% 4.71%
Rates are subject to change without notice.
Rates last updated xx/xx/xxxx
*Annual Percentage Yield

I've seen several websites that have this type of set up and no links to disclosures. Then I've seen other websites with the loan program, rate, and APR with links to disclosures. To me, the latter seems more compliant. I notice on the websites with the links that the (conforming) isn't included with the program name. Is that the clincher?
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#2190996 - 08/29/18 02:16 PM Re: Mortgage Rates on Website Bec
Adam Witmer Offline
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Well, a web page is an "advertisement" and "15 year fixed" is a trigger term for closed-end loans. Exclude the term (on closed-end loans) and you don't have a need for other disclosures.

Originally Posted By Bec
Then I've seen other websites with the loan program, rate, and APR with links to disclosures.

From what I have see, I would guess that less than half of websites get Reg Z advertising rules correct.
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#2191004 - 08/29/18 02:40 PM Re: Mortgage Rates on Website Bec
Bec Offline
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The Great White North
So if you remove the term "fixed" you're in the clear? If you keep it, the one-click link is required?
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#2191007 - 08/29/18 02:51 PM Re: Mortgage Rates on Website Bec
rlcarey Online
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rlcarey
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Galveston, TX
The term. i.e., "15 year" is the trigger not the word fixed.
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#2191011 - 08/29/18 02:56 PM Re: Mortgage Rates on Website Bec
Bec Offline
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The Great White North
Got it, thanks!
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#2191021 - 08/29/18 03:15 PM Re: Mortgage Rates on Website Adam Witmer
Richard Insley Offline
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Richard Insley
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Toano, VA
Originally Posted By Adam Witmer
From what I have see, I would guess that less than half of websites get Reg Z advertising rules correct.
Sounds about right...and that's a HUGE improvement over the dismal level of compliance years ago.

If the regulators cared about this, they could clean it up in a matter of weeks. If I can search on "rates" + "Member FDIC" and find bank after bank violating the loan (and sometimes deposit) advertising rules, they could too. Print the page, attach it to form letter on agency letterhead, and mail to the bank's CEO. Recheck in one month and tighten the screws on those who haven't improved.
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#2191222 - 08/30/18 03:34 PM Re: Mortgage Rates on Website Bec
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,584
Bloomington, IN
We disclose the following.

Please call us at XXX-XXX-XXXX for rates and products not published. Current posted rates are in effect as of XX/XX/XXXX. Rates are subject to change without notice.

A 30 Year Fixed Rate Mortgage at the current published rate will result in 360 payments at $X.XX per $1,000 borrowed.

A 15 Year Fixed Rate Mortgage at the current published rate will result in 180 payments at $X.XX per $1,000 borrowed.
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#2191405 - 08/31/18 03:49 PM Re: Mortgage Rates on Website Bec
happyhelen Offline
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Joined: Nov 2017
Posts: 3
Could I ask how lenders are disclosing adjustable rate mortgages? Trying to finalizing reading the Reg to determine if we have to disclose all subsequent payment streams in the add when there is a discounted period and whether we show payment stream until we reach the fully indexed rate or the life cap when advertising?

Any feedback will be helpful.

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#2191422 - 08/31/18 04:30 PM Re: Mortgage Rates on Website Bec
Rocky P Offline
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Posts: 7,682
Florida
HH - google any of the major lenders - the information is available. E.G. BoA

https://www.bankofamerica.com/mortgage/a...gage#product555
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