Advertising Introductory Interest Rate for HELOC

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Question:

We are interested in advertising our introductory interest rate for our HELOC on the side of a bus. Should we treat it just like a newspaper advertisement with all of the same disclosures based on the triggers?

Answer:

Yes. There really is no other option. There are no exemptions from TIL advertising disclosure requirements like the ones in TISA for billboards, electronic media, etc.