I am confused by the Truth in Lending rules and FTC Guidance (How to Advertise Consumer Credit) on how to advertise the following product: 10/1 LIBOR ARM. Repayments are "interest only" for 10 years with a fixed rate, then for the remaining 20 years (30-year loan), the rate becomes variable and the loan is amortized for principal and interest payments. At a minimum, our line of business wants to advertise the amount of the monthly payment. Is this a Graduated Payment feature loan, or a Discounted Variable Rate Plan or something else? Any real-life examples are appreciated.
My question relates to the FCRA and the ability of a bank, or other lending institution, to internally cross-sell. Let's say that a bank does a credit check (for a proper purpose under FCRA) to determine whether a potential borrower would be approved for a mortgage. Based on the information contained in the credit report, the bank then solicits the potential borrower to also obtain a HELOC. The HELOC is also done through the bank, although in a separate department, and another credit check would be pulled in connection with the HELOC if it was pursued by the potential borrower. Is this prohibited by FCRA? I have looked at the provisions of the act and it does not seem to be expressly prohibited.
What is the proper mailing address for the Federal Trade Commission for an adverse action notice?