Help - can somebody help me with rate information that we list on our website? I have been reading thru Regulation Z and I feel like I have figured out some information/disclosures we need to add to our website, but I was wondering if anyone could help me out and let me know if I'm on the right track or missing anything? I am going to post some examples from our website:


Adj. Rate Mortgage Loan Rates
Product - 1 Year ARM
Rate - 4.375%
Annual Percentage Rate - 5.267%
Points/Fees - 0.00%/call for fees
Terms - up to 30 years
Margin - 2.50
Comments - Adjustments based on 1 year Treasury

Fixed Rate Mortgage Loan Rates
Product - 15 Year Fixed
Rate - 4.625%
Annual Percentage Rate - 4.785%
Points/Fees - 0 Points
Terms - 15 years
Margin - N/A
Comments - Blank

Rate Modification Rates
Product - 15 Year Fixed
Rate - 5.125%
Annual Percentage Rate - 5.2870%
Comments - Updated Income Verification Required. Loan must meet modification requirements

Home Equity Line of Credit and Home Equity Loan
Product - Home Equity LOC - No Closing Costs
Annual Percentage Rate - TBD
Payments - The amount of accrued interest on the last day of the billing cycle
Repay Terms - 15 Years
Comment - (first mortgage balance + the credit line) < or = 80% of the appraised value of your home.

Product - Home Equity Loan
Annual Percentage Rate - TBD
Payments - Fixed
Repay Terms - 5 Years
Comment - (first mortgage balance + the credit line) < or = 80% of the appraised value of your home

Installment Loan Rates effective as of 11/20/2018
Product - Auto New
Terms - up to 60 months
Comments - Please call for details

I believe in the mortgage rates area we need to add the total down payment amount and the terms of repayment per Reg Z. I also believe we need to add a statement saying that the rates are subject to change without notice in the adjustable rate area. Also - in the HELOC and HE area we state "no closing costs". Is this a triggering term that requires more disclosures per Reg Z?

I'm sorry this is so long - I just wanted to give an example and see if I'm on the right track. I honestly wish we didn't even list rates on our website.

Thanks for any help you can provide!

I would recommend pushing for removal of rates. There are trigger terms through all of your examples, and you will need to write pages of footnotes, disclosures, etc.

I have worked on "rates as low as" campaigns, but with the assistance of compliance attorneys ($$$).

best of luck!

The rate environment has been fairly steady. Think of all the maintenance you will need to do when the rates start moving, plus the calculations and possibilities for error. One thing is a representative rate, the other are actual rates, which yours appears to be. .

Rates are only trigger terms for the open-end products. "Term of the transaction" is a trigger term for closed-end, and the OP's example is riddled with information about repayment periods. Add the two different sets of infractions and it's obvious that the whole rateboard page needs to go.

Thank you all. I appreciate all of your responses. I am going to discuss this today with the loan department.

Be prepared for the old "but other banks do it this way" and "it must be OK because our regulators have never criticized it before" arguments. Just because the regulators have done a terrible job enforcing compliance with these advertising rules there's no assurance they will continue ignoring them. The safest, and in the long run, cheapest, way to run your bank is to do things right the first time.