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?

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.


From what I have see, I would guess that less than half of websites get Reg Z advertising rules correct.

So if you remove the term "fixed" you're in the clear? If you keep it, the one-click link is required?

The term. i.e., "15 year" is the trigger not the word fixed.

Got it, thanks!

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.

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.

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.

HH - google any of the major lenders - the information is available. E.G. BoA

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