Reg Z & Interior Billboard Promotion Requirements

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Question:

I am reviewing an interior billboard promotion for a home equity credit line and I've looked everywhere in Reg Z (is that possible?) for the answer to this: The ONLY print copy in the ad reads, "X% less than Prime (for the life of the loan) Ask about our Home Equity Credit Line." Is this ambiguous enough to avoid all the implicit terms disclosures required under 226.16(b), namely, from 226.6?

Answer:

Check with your regulator to see how this type of advertisement is viewed. I've heard of at least one agency that cites this as a problem.

First published on BankersOnline.com 5/29/06