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Guidance Needed on Direct Mail Ad

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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?

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 1/18/10

First published on 01/18/2010

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