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#888 - 03/13/01 05:35 AM Radio Advertising
Jan94 Offline
Platinum Poster
Joined: Mar 2001
Posts: 828
For a HELOC promotion, this is a 60 sec radio advertisement that will mention "no closing costs". Since this is radio, do we need to provide any additional disclosures? We will be saying Equal Housing Lender. Thank you.

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#889 - 03/12/01 08:11 PM Re: Radio Advertising
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,700
Cape Cod
If you advertize HELOCs with "no closing costs," you need to consider the Commentary to Reg Z section 226.16(d)(4):
4. Misleading terms prohibited. Under 226.16(d)(5), advertisements may not refer to home equity plans as free money or use other misleading terms. For example, an advertisement could not state “no closing costs” or “we waive closing costs” if consumers may be required to pay any closing costs, such as recordation fees. In the case of property insurance, however, a creditor may state, for example, “no closing costs” even if property insurance may be required, as long as the creditor also provides a statement that such insurance may be required. (See the commentary to this section regarding fees to open a plan.)

As far as I know, there is no special exemption for radio ads here.

John Burnett
Cape Cod Bank and Trust

John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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