Is there any potential problem with this statement?

"Right now, qualified borrowers could save with auto loan rates as low as 4.99% for 48 months."

Also, could we say "as low as 4.74% for 48 months" if we have a rate discount for automatic withdrawal even though customers could choose not to take advantage of this discount?

We're a very small community bank with very little in the way of marketing. Any input is very appreciated.

I assume this is a fixed rate. You must state the APR, using that term. (you can also state the rate) Mentioning the term (48 mo), triggers other disclosures. See section 226.24 of Reg Z.

2nd question - If you are adv the rate discount, then I would footnote the fact that the cust has to have automatic pmts to get the rate.