It has been a very long time since I've looked at any marketing material, so please help

It is my understanding that you can list a rate (e.g. 5.50% - 1.5 Points) - should we also show "APR" nest to the rate?

Also, if you list something like 80% LTC to $500,000 - is this a triggering term? or 75% LTV to $200,00.

If the flyer shows a percentage offering a rebate if a lot loan is rolled into a construction, is there any thing we should be aware of?

Not sure of the last question, but to your first question, yes, the APR must appear in equal prominence as the rate. As to your 2nd question, I believe the correct answer would be that if your fees/rates for 80% versus 75% LTV are different in any way which would affect the APR, it would trigger APR disclosures for each program. I would wait for another answer to that one though.

Does it matter if the flyer only goes to brokers, and is not for public distribution?

No

Thank you, so if we have a flyer that lists a rate, point, and a term - this would trigger additional disclosures (eg what a payment would be?)

yep

If this is truly a B2B communication and will not reach borrowing consumers, then it is not covered by Reg. Z's advertising rules. See the OSC to Section 226.2(a)(2) for discussion of communications that are not advertisements.

If the promo piece IS reaching consumers and it contains rates, then it requires both the APR and the simple rate, not just the simple rate with the letters "APR" next to it. Assuming you have also mentioned the term of the transaction (30 yrs, 360 pmts, etc.) then you are also on the hook for a full disclosure of a payment schedule for a representative credit amount at the APR quoted.

I believe your second question relates to "downpayment" as a trigger term. By mentioning different LTVs, you are indirectly advertising the amount or percentage of downpayment. Reading Section 226.24 carefully, you will find the reference to the definition of "downpayment." That definition limits "downpayment" to credit sale transactions--not ordinary loans. Unless you are advertising credit sales, "downpayment" is not a trigger term.

Good Morning Richard -
The flyer in question will be going to brokers only outlining several different products (e.g.1-time close const., remodel/2nd TD, Lot lns, Mfg. lns etc.) For each plan it shows what we can offer and who to contact. Our flyer does state that the information is for Mortgage professionals only, and not for distribution to consumers etc.
So, would you say, that because this is for our in-house purposes only, that we are safe with not stating the "APR" behind a rate, and where a product mentions a LTC (loan to close??) etc. that we are okay.

I would be very careful, not only because end-customers will undoubtedly be shown this sheet, but also, brokers are trying to compare apples to apples as well, so even if the regulations give you the opportunity to leave off APR info on this broker sheet, I guess I wonder why you would want to.