I have looked high and low for guidance on this and am having little success. We want to offer to "waive one year annual fee on new or existing Home Equity Lines of Credit" to our long time (20+ years) customers. Reg Z states that any negative or positive fee information is a triggering term, but I don't know if it applies in this situation. This will be sent as a statement insert to those customers only. Our HELOCs are open-ended credit products. Is this considered a triggering term in this situation?
Does the one click rule apply for required disclosures when advertising with a banner on the website for home equity products featuring a discounted introductory rate?
We plan to advertise our home equity loans and HELOCs in a radio ad that will say the APR for each of these loan products. What are the rules for disclosures on the radio? Do the same triggers apply to print ads?
If the term of an advertised home equity loan is buried in the fine print rather than used in the body of the ad, is it still considered a "triggering" term that would require us to add "$xx.xx per month per $1000 borrowed" to the fine print?
I saw a dry erase board posted in front of a competitor’s bank branch in a grocery store with the following:Credit Card Debt …………$1,000Kitchen Remodel……………$8,000Medical Bills……………………$2,500Cruise/Vacation……………$5,000Ask about a Home Equity Loan from Bank of [Name of Bank Withheld]Are these loan amounts considered trigger terms or is this even considered an “advertisement” since it is only on a dry erase board in front of the branch in the grocery store?
Is there any restrictions on giving a customer a bonus, such as a $100.00 gift card, for opening a home equity line or loan?
We offer a Home Equity Line of Credit that may convert all or part of outstanding balances to a Fixed Home Equity Loan. I'd like to advertise that we do not charge any fees for conversion or annual fees to have the line of credit. I'm told that if I say "No Fees" that it triggers disclosure of APR, that it's a variable rate, the maximum APR and property insurance may be required. Is there any way to just advertise a no fee line of credit without stating an APR?
On Mobile Phone ads, the logo for Equal Housing Lender can't be displayed. Is it permissible to display only the text "Equal Housing Lender" on ads for home equity loans?
I am reviewing an interior billboard promotion for a home equity credit line and I've looked everywhere in Reg Z (is that possible?) for the answer to this: The ONLY print copy in the ad reads, "X% less than Prime (for the life of the loan) Ask about our Home Equity Credit Line." Is this ambiguous enough to avoid all the implicit terms disclosures required under 226.16(b), namely, from 226.6?
We want to start a promotion where we notify customers that they have been pre-approved for a Home Equity loan, what guidance can you provide and what regulation should I look at?