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Guidance Needed on Direct Mail Ad

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Question: 
We have a direct mail letter going out that has a coupon for $150 off closing costs for a new mortgage and no closing costs for a home equity. We do not advertise any rates, as this will be an ongoing mailing. What do we need to disclose?
Answer: 

If you are referring solely to closed end loans, neither present a disclosure issue from a TIL perspective. If the home equity loans you are referring to is HELOCs, then "no closing costs" triggers all home equity open-end credit advertising disclosures. Also, make sure you know how this program is going to impact your RESPA disclosures on an ongoing basis.

First published on BankersOnline.com 1/18/10

First published on 01/18/2010

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