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Telemarketing Script for Closed-End 1st Mortgages

Answered by: 
Randy Carey

Question: 
I am reviewing a telemarketing script for closed-end first mortgages. Information from a consumer credit report will be used to extend a pre-qualification offer which states "you have been pre-qualified for a mortgage loan from $85,000 to $220,000. Our offer includes an APR range from 5.22% to 7.88% for a fixed rate of 30 years." Can an APR range be used? Also, I think the term "30 years" is a trigger. Please advise.
Answer: 

Before you tackle the advertising rules, I suggest you review the prescreening requirements under the FCRA. An offer of credit between $85,000 and $220,000 with a range of APRs is not a "firm offer of credit" under the FCRA. I would suggest that you begin by reading this document:http://www.fdic.gov/regulations/laws/rules/5000-2900.html

First published on BankersOnline.com 6/20/11

First published on 06/20/2011

Filed under: 
Operations
Filed under operations as: 
Credit Report
Telemarketing

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