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#989444 - 07/08/08 01:43 PM Advertising bank-owned repos for sale in newspaper
Many Hats Offline
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Joined: May 2008
Posts: 915
Orlando, FL
We have a few manufactured homes (without land) that we took in reposession.

We want to place an ad in the paper. Are there any special disclosure requirements since this is considered a credit sale?

And, if we offered a $500 Home Depot card (or gas card) as an incentive, would this be okay?

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#989459 - 07/08/08 01:50 PM Re: Advertising bank-owned repos for sale in newspaper Many Hats
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
If you state the amount of down payment (or the percentage you're willing to lend), you trigger further disclosures. This is the only thing unique about credit sales.

There's no problem with offering the incentive that I'm aware of.
_________________________
David Dickinson
http://www.bankerscompliance.com

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#989469 - 07/08/08 01:57 PM Re: Advertising bank-owned repos for sale in newspaper David Dickinson
Many Hats Offline
Platinum Poster
Joined: May 2008
Posts: 915
Orlando, FL
If we do indicate that a certain down payment is required...or that will will finance up to a certain percentage....where can I find the information regarding the exact disclosures that will be required?

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#989487 - 07/08/08 02:09 PM Re: Advertising bank-owned repos for sale in newspaper Many Hats
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,416
Bloomington, IN
Reg. Z 226.24(c) and its Commentary.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#989497 - 07/08/08 02:11 PM Re: Advertising bank-owned repos for sale in newspaper Dan Persfull
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
This is exactly the type of thing we will be discussing in the upcoming Advertising Webinar (7/16):
http://calendar.bollearningconnect.com/main.php?view=event&eventid=1205417013387
_________________________
David Dickinson
http://www.bankerscompliance.com

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#989758 - 07/08/08 04:57 PM Re: Advertising bank-owned repos for sale in newsp Many Hats
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 9,995
Toano, VA
Originally Posted By: Many Hats
where can I find the information regarding the exact disclosures that will be required?

Keep a link to this publication handy.
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...gone fishing.

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