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Advertising Rate Sheet-"Limited Time Offer"

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Question: 
We are creating a rate sheet to be used by local Realtors. It will provide the current rates for several types of loan products. Under our in-house loan category, Marketing would like to list "Limited Time Offer" as one of the bullet points. I recommended they provide an expiration date. Marketing wants to show that as follows - "Limited Time Offer. May Expire Without Notice." Since UDAAP is governed by perception of the reader what are your thoughts, I am still leaning toward a hard expiration date. What is required, or commonly done?
Answer: 

UDAAP should always be in the back of your mind. Given the right circumstances, almost anything you say or do could be construed as unfair or deceptive.

Assuming the rates are for consumer loans, then Reg. Z's "bait and switch" prohibition also comes into play. Whether or not you want these rate sheets to find their way into the hands of consumers, that will happen. When it does, you're subject to a specific rule.

Section 1026.24(a) says " If an advertisement for credit states specific credit terms, it shall state only those terms that actually are or will be arranged or offered by the creditor." This is an open-ended rule, so with the passage of time, violations are inevitable unless you state an expiration date and take steps to assure that the rates and other terms stated in the rate sheet are actually available through the expiration date.

First published on 05/09/2021

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