We would like to hang Home Equity Line banners with the phrase "Rates as low as" and then show our 6 month Intro APY. Are banners and outdoor ads subject to full disclosure under Reg Z? How much disclosure do I really need to include?
We have tiered our Home Equity Loan rates based on dollar amount. $25,000 and above get one rate then dollar amounts below $25,000 get a higher rate. Do I have to disclose both rates or can I just advertise the rate associated with the $25,000 and state that it is for amounts $25,000 and greater?
Is it imperative to disclose pre-payment penalties in home equity loan advertisements?
We currently offer an Affinity Group Banking Program to employees of qualified business customers. In our brochure to business customers, we would like to list one of the benefits as follows "A special banking package available to your employees, includes... discounted rates of Prime - 1% on Home Equity Lines of Credit" (exact wording). The discounted rate applies for the life of the loan. Does the use of "discounted rate of Prime - 1%" require an example of what a typical payment would be with and without the discount?
Our marketing group came up with a new ad where we would mail CPAs a free 50 minute phone card. It is supposed to get our name out to this group as a referral source. The ad says (among other things) "Be sure to recommend xxx Bank to any of your clients who would benefit from our personalized approach to banking." If this ad is universal across the board to our CPAs and not tied specifically a consumer real estate transaction, could we have a RESPA Section 8 issue, if a CPA refers someone to the bank for a Home Equity Loan, or a personal residential mortgage?
We are in the process of changing the vendor for our Internet banking service. As a result, the look and feel of that part of our Web site will change. Any advice about customer impact?
Chase is offering several programs that offer cardholders airline miles for use of their credit cards.
Is it a RESPA violation to offer consumers a referral fee for referring a customer to a Bank for a home equity line of credit?
I am trying to get a question answered related to HELOCs that have attached credit cards. Are these plans excluded from the requirements under 226.5a? We currently have Home Equity Visa Lines of Credit and are looking to do a direct mail promotion where we have a balance transfer option for a 6 mos period at a lower rate. My question is, can we disclose the different rates for purchases, cash advances, balance transfers, etc., in our HELOC disclosures, or must we have a separate disclosure in a "tabular" format, like we would on our normal direct mail solicitations for a regular credit card product?
Overall, American consumers have a long way to go in understanding exactly what a credit score is, according to two recent surveys.