Rate sheet content

Answered by:

Question:

If we have a rate sheet that we give to real estate agents and our loan originators, but we know the true use will be for them to hand it to consumers or post it where consumers can readily access it, wouldn't we need to have the APR on it?

Answer:

Yes. While the Commentary tells us, “ informational material, for example, interest rate and loan term memos, distributed only to business entities” are not advertisements, if you know the information will be given out to consumers, I would recommend including the required advertising disclosures.

-----------------------------

Learn more about Andy Zavoina’s webinar Advertising – Don’t you UDAAP