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#1728083 - 08/07/12 03:39 PM Residential Mortgage Loan Advertising
blast2 Offline
Member
Joined: Jun 2010
Posts: 99
Where can I find a good and useable explanation of the rules on advertising rates and terms for residential mortgage loans.

Our bank wants to begin advertising residential mortgage loan rates. Until now our advertising has been very generic and contained no reference to rates and/or terms so I have not spent much tme on that issue. I am aware that the current rules are very specific and require care in preparation.

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#1728100 - 08/07/12 04:06 PM Re: Residential Mortgage Loan Advertising blast2
MyBrainHurts Offline
Platinum Poster
Joined: Feb 2010
Posts: 960
Illinois
You're right that they are very specific. I always go straight to the reg when marketing tosses a new ad on my desk. Here's the BOL page for it:
http://www.bankersonline.com/regs/12-1026/12-1026-000.html

Note that there are separate sections, and very different rules for open end and closed end loans.

Also, here's the checklist Jim Bedsole posted in Bankers Tools:
http://www.bankersonline.com/tools/marketingchecklist.pdf

Last edited by MyBrainHurts; 08/07/12 04:10 PM.
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#1728107 - 08/07/12 04:21 PM Re: Residential Mortgage Loan Advertising MyBrainHurts
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,231
Toano, VA
Originally Posted By: MyBrainHurts
the checklist Jim Bedsole posted

Note, however, that this tool ia almost 10 years old.
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#1728811 - 08/08/12 06:16 PM Re: Residential Mortgage Loan Advertising blast2
blast2 Offline
Member
Joined: Jun 2010
Posts: 99
Thanks mybrainhurts for the advice and the link. It has been very helpful

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#1728969 - 08/08/12 08:50 PM Re: Residential Mortgage Loan Advertising blast2
blast2 Offline
Member
Joined: Jun 2010
Posts: 99
Follow up question. The link to the regulation provided by MyBrainHurts pulls up Subpart C - Closed-end Credit. On the first page in paragraph 1026.24(d)(1)four "triggering terms" are listed. Advertising any one of the "triggering terms" requires additional disclosures from paragraph (d)(2). My question is: does the advertisement of any one triggering term require disclosure of ALL the (d)(2) disclosures or only the ones that correspond to the triggering term advertised. Note the wording "as applicable" in (d)(2)? Logic would say only the corresponding disclosures, but it doesn't specifically say that.

Has anyone else struggled with this and can you give some input.

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#1729006 - 08/08/12 09:58 PM Re: Residential Mortgage Loan Advertising blast2
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,817
Florida
If i, ii, iii or iv, from (d)(1)
then use all of (d)(2) i, ii, and iii.

Or another way -
If a Chinese menu -
1 from column A = all of column B.
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