I have a question about the use of the Equal Housing Lender logo. Does it need to be included in a mortgage company email signature?
I am new to lending compliance and have an advertising question. My bank wants to advertise the following:
"Enjoy our special 20-year financing offer. Ask us for details."
I am of the opinion that "20 year financing" is a trigger term and therefore requires APR, down payment and repayment terms. My predecessor disagrees
because an interest rate is not quoted.
Along the same lines, if an advertisement says, "15 and 30 year fixed rate loans available" would we have to disclose rate and payment options for both
terms assuming this is a trigger term?
Is there a complete list of triggering terms for open-end credit (credit cards namely) somewhere? I have scoured the internet and cannot find a definitive list.
If we are calling a current mortgage customer to let them know they may qualify for a lower rate with a refinance, are these internal customers required to be ran through the FTC Do-Not-Call list?
I am trying to find out what the federal regulators would require we have on a Conditional Approval Letter issued to a borrower. Like the FDIC logo, Equal Housing, etc. What does ECOA require be on this letter?
We include the Equal Housing Lender logo in all our home loan ads. Are we also required to include the “Equal Opportunity Lender” logo?
Does a mortgage lending officer have to display any compliance logos for a "finance provided by" sign posted in a yard?
What is the current advertising record retention requirements for TILA, RESPA and TIS advertising?
What if a consumer is prequalifying for a loan and wants a cost estimate. Since the estimate also contains the loan amount, rate, payment, as well as the fees, (trigger terms) shouldn't it also contain the APR, or is it ok to allow this requirement to slide on the basis that it is similar to giving a real estate office or newspaper your rates?
Our bank offers commercial mortgages as well as mixed use and multi-family lending. Do we need to include Equal Housing Lender and dog house on our advertising and marketing materials for any of these products?