Fixed Rate Mortgages

Would stating that we offer fixed rate mortgages require any additional disclosures under 1026.24 i(1) Misleading advertising of “fixed” rates and payments? We offer truely fixed rate amortizing loans but we also offer adjustable rate loans and balloons.

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Can we advertise that we offer fixed rate mortgages without disclosing all the other variable loan terms we also offer?

I think you can but why not mention that they contact you for information about other available loan programs.

It is just a general list of products and it says we offer fixed and variable rate mortgages but we were told this violated 1026.24i(1) since we also offer balloon loans and 12 month bridge and construction loans.

Pretty much they are saying it is wrong if we say we offer fixed rate mortgages unless all of our loans are truly fixed.

First: who is "they"?

Second: You are only advertising your Fixed-Rate Mortgages and your Variable-Rate Mortgages. There is abosolutely no requirement to advertise all of your products that may be available. You offer what you say, there is nothing misleading about that.

Whoever "they" is, "they" are way off base.

They are auditors not examiners and I completely disagreed with the finding and that is why I wanted some input from this board. Thanks for your help and I am glad that I am not the only one thinking they are way off base.

Kick this up to their head office and find some new auditors if they continue to push this.