Is it ok to state the variable rate disclosure part - "For variable-rate accounts, a statement that the rate may change after the account is opened."

In a footnote?


Thanks

I'm unsure of your context here. As an example UDA(A)P problems have been cited when the front of an add said one thing, but page 2 clarified this was an adjustable rate - in this case a mortgage but the same issues apply.

If anything is misleading, a disclosure later is generally not sufficient to "make it OK."

As to TISA specifically, if the footnote is buried that may be a hard test to pass unless the footnote is called out in an obvious manner and it's easy to find and read.