Specific Disclosures for Mortgage Ad

Question:

We want to place a mortgage ad and use the following: If the interest rate is over 4.00% on your home loan, you may be able to refinance at a lower rate. Are there specific disclosures that would have to be made in this scenario or is it fine as is?

Answer:

As far as Reg. Z, and Reg. B, the verbiage does not trigger any required disclosures. You will need the Fair Housing logo and verbiage. You might consider adding some language regarding borrower creditworthiness standards to protect against possible UDAAP problems.

First published on BankersOnline.com 4/29/13