We have just reconstructed our rate sheets to be more user friendly. We would like to share these rate sheets with brokers that we contract with. There are not any disclosures on the rate sheets except "FOR INTERNAL USE ONLY, NOT TO BE DISTRIBUTED TO THE PUBLIC". Is this acceptable for broker usage, or do we need to put disclosures on the rate sheet?

Also, if an internal originator or a broker uses our rate sheets to point something out to a customer do we need to have the disclosures on there to perform such action?

Thank you in advance.

anyone?

The advertising exclusion you are looking for is in the commentary, and states these are not advertising:

" B. Informational material, for example, interest rate and loan term memos, distributed only to business entities. "

IMHO, if it is shared, it should conform.