Advertising rates

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Question:

If we price HELOCs based on the applicant's credit score and loan to value ratio, so some borrowers get a lower rate than other borrowers, can we disclose the lower rate in our advertisement, or do we need to disclose both rates? Do we also need to specify the criteria for receiving the lower rate?

Answer:

You do not have to show both rates. In your ad you could state something like “rates as low as ___” and disclose the lower rate so long as that is a valid statement and not a “bait and switch” tactic. It is always recommended that you keep any calculations and supporting documentation to show your examiners if they ask. This helps prove the advertised rate is attainable and not deceptive.

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