Including a Disclosure in Marketing Materials

If I understand the question, you are offering a rate that is only available for new credit, not for refi deals. If that is the case, then absolutely, your advertisement should say that. I can't point you to a specific requirement that says this, but Reg Z says your advertised terms and conditions must actually be available. Unfair and Deceptive Acts and Practices requirements stipulate that your advertisements must not be misleading or deceptive, so I would absolutely include a disclaimer that says the terms are available for new credit only.

First published on BankersOnline.com 7/26/10