We are currently in the middle of a HELOC promotion and with the change in prime rate our floor rate is increasing. Our paper promotional ads, flyers and posters, have a clause in there that the minimum APR will not be less than 3.25% The ad does also state that these rates and terms are effective as of 2/14/2022.

We can update the minimum APR on all electronic advertisements easily. I am wondering if there is a requirement that you must update this information if it changes in the middle of a promotion? I don't believe the minimum APR is a requirement for disclosure but we did it so I feel like we need to update it. Asking as recreating paper marketing materials is costly.

Thanks.

As long as you have the date in there, I think you are OK. How long is the promotion going to be running?

It appears the floor is based on Prime.

You may want to consider: Minimum rate after the introductory period will be the then Prime Rate published in the Wall Street Journal.

or

these rates and terms are effective as of 2/14/2022 and subject to change without notice.

Otherwise I agree with Randy that you should be OK with the "as of" date.