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#533470 - 04/19/06 04:00 PM Advertising fixed rate mortgage
Peepers Offline
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Joined: Jul 2002
Posts: 13,994
How often does anyone see the need to have to disclose the amount or percentage of down payment in a closed end ad?

This would apply only in a credit sale transaction which by definition is a transaction in which the seller is a creditor.

We’re a creditor but not a seller.

Is this disclosure most likely seen when advertising sale of foreclosed property?
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#533471 - 04/19/06 05:39 PM Re: Advertising fixed rate mortgage
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
You can mention the term "down payment" or "20% down" in an ad without it being considered a "down payment" as defined in the regulation, as long as you are not a seller in the transaction. For a bank, credit sales most often arise when selling foreclosed real estate or other repossessed collateral (automobiles, for example).
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BankersOnline.com
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#533472 - 04/20/06 02:33 PM Re: Advertising fixed rate mortgage
Peepers Offline
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Joined: Jul 2002
Posts: 13,994
Thank you John
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