Good Morning - we are currently running a home equity loan sale. We are creating a TV ad about the loan sale. We do mention in the advertisement that there are "no closing costs". I know this is a triggering term if there are any type of closing fees. The only fee we have is a $25 mortgage release fee due at payoff. At the end of this advertisement it is said that there is a minimum $10,000 loan amount, property insurance may be required and a $25 mortgage release fee is due at payoff. Since this is stated, would we be ok with saying "no closing costs"? Also - we mention that the sale goes thru the end of November, but list no specific date. Is this ok?

Thanks for any help!

So, to update a little on this. I talked to our Mortgage loan officer and verified that the sale includes both open and closed end loans. Because of this, then I believe we must include the following disclosures since we are using the term "no closing costs":

i) Any loan fee that is a percentage of the credit limit under the plan and an estimate of any other fees imposed for opening the plan, stated as a single dollar amount or a reasonable range.

(ii) Any periodic rate used to compute the finance charge, expressed as an annual percentage rate as determined under section Sec. 226.14(b).

(iii) The maximum annual percentage rate that may be imposed in a variable-rate plan.

Just trying to verify that I am on the right path. Also - is the $25 mortgage release fee due at payoff considered a "closing cost" or is this a non-issue since we mention it at the end?

Thanks again for any input!