Yearly Archives: 2014

Not all states have a disclosure requirement. You should disclose the following in all ads:

• The licensed name of your company
• Your company’s licensed address
• Your toll free phone number
• NMLS ID #
• Equal Housing Lender Logo

Here’s an example of state required Disclosures for a 50 state licenses mortgage lender. Check with your compliance officer or attorney when preparing your version of such a provision in your mortgage ads. This sample will help you get on your way to having a fifty state required disclosure for mailer type mortgage ad mailed nation wide.

Here it is:

All loan programs are offered by Main Street Mortgage, Inc. 33 Main Street, Anytown, Pennsylvania, Zip. 888-555-5555/  All loans will be secured by a lien against your property. Not all applicants will be approved. Terms and conditions apply, call for details. AZ Mortgage Banker License No. 1234567; Licensed by the Department of Business Oversight under the California Residential Mortgage Lending Act License No. 1234567; Regulated by the Colorado Division of Real Estate; GA Residential Mortgage License No. 1234567; IL Residential Mortgage Licensee # 1234567; IL Residential Mortgage Licensee MB.1234567 – Department of Financial Regulation; MA Mortgage Lender & Mortgage Broker License No. MC1234567; Licensed by the Mississippi Department of Banking and Consumer Finance; Licensed by the New Hampshire Banking Department; NJ Residential Mortgage Lender License; Licensed Mortgage Banker – NYS Department of Financial Services; OH Mortgage Broker Act Mortgage Banker Exemption No. MBMB.1234567; OR Mortgage Lender License # ML-1234567; Rhode Island Licensed Lender; VA Exempt Company Registration; WA Consumer Loan License No. CL-1234567; NMLS No. 1234567.

Let’s look at an Advertisement for a 10-1 ARM Loan:

This ad has a really big 3.250% Interest rate. That’s low right?  But wait, doesn’t Regulation Z require the APR to be same size font and and apperance as the interest rate?

How’s the disclosure on this advertisement?  Lets look at the back side:

The disclaimer is pretty good:  It has the rate available as of date (August 1, 2014), has the necessary FICO score, indicates that the loan is an ARM and that the payment is subject to change, says max LTV and CLTV, indicates that ad is for no cash out refi, owner occupied, and shows how and when the payment can/will change:

APR is Annual Percentage Rate and is current as of August 1, 2014. Rate based on 10/1 ARM, with no more than 70% LTV and CLTV.  $749 origination fee less a $300 savings …