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#1998866 - 02/27/15 06:54 PM 5/3 ARM
TooManyQ Offline
New Poster
Joined: Jul 2012
Posts: 12
I haven't reviewed Marketing Compliance for 7 years, with that said, my lenders are telling me that I am requiring language that they haven't used and it has never been an issue. Am I way out in left field?

1)I used to make sure all Res. Loans stated "subject to credit approval" - they believe that "qualified applicants only" is sufficient.
2) With an ARM, I always stated "rate may increase/change" - is this not needed?
3)With a discounted rate, I have always required "initial interest rate may/does reflect a discount.
4) and a statement that "APRs are based on $xx.xx with a LTV of xx.xx%."

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Marketing
#1998908 - 02/27/15 07:41 PM Re: 5/3 ARM TooManyQ
Reads Regs Offline
Diamond Poster
Joined: Nov 2004
Posts: 2,308
If the loan is subject to Reg. Z, see section 1026.24 and its commentary for the advertising rules for closed-end credit.

The subject to credit approval is not something from Reg. Z. I believe creditors include this phrase to avoid any potential "UDAP" concerns.
_________________________
Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.

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#1999005 - 02/27/15 09:53 PM Re: 5/3 ARM TooManyQ
TooManyQ Offline
New Poster
Joined: Jul 2012
Posts: 12
thank you

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