Admin


About Admin

Our team has extensive experience in reviewing mortgage advertisements and advising clients about mortgage compliance issues including use of Compliance Management Systems, State and Federal compliance matters, and running the Legal and Compliance departments of major mortgage banking entities.

Our company has Advertising Quick Hits learning Guides available as well as a self-study six week E-Course that will help your team member, or you, become more skilled at becoming an Advertising Compliance Officer for your company.


Model ARM Disclosure – Adjustable Rate Mortgage Ad

So you want to place an add for a 5/1 ARM on a flyer, a mailer, a banner ad, a Facebook post? What needs to be in that ad? Lets assume you have some triggering terms like a payment amount or an interest rate so you will need to make all applicable disclosures.ARM Rates

Here’s the list of what must be your ad:
1) The APR (annual percentage rate). This should be listed right next to the statement of the interest rate – in same size font and same font color etc. It must be clear and conspicuous.
2) Make sure its clear that your ad in an adjustable rate mortgage loan (ARM) product and do not hide this fact.
3) State the effective date of the interest rate you have displayed.
4) Include a statement that the rates are subject to change.
5) State the payment amount during the initial five year period.
6) And here’s the tricky part – state that remaining terms of the repayment. This requires you to tell the borrower how the payment will change after the five years are up.

Need more info, check out the Advertising Disclosure Samples at our main site: www.advertiseyourloans.com


Sidewalk Sale on Mortgages?

Mortgage Ads on the Sidewalk? I was walking through a business area to get coffee while my car was getting some work done at a repair shop when I came across this mortgage ad. I noticed no licensing information, no company name, in fact no name at all, just a phone number. Does this person need a license to lend his or her own money? I’m pretty sure they do though although there may still be an exception from licensing if you only make a couple of loans per year or you are carrying back financing as the seller of a property. So I guess it all comes down to how effective this sidewalk advertising really is and how much business (if any) this entrepreneur is getting,
By the way, I’m convinced that the ad is a sidewalk ad like those ones you see in supermarket aisles that are affixed to the floor. I don’t think that this ad fell off a sign post and landed there on the sidewalk. Could this be the new wave of the future or is this just “littering? Only time will tell.


Watch out for increase in state investigative complaints about mortgage loan advertising

State regulators are on the prowl right now and are super interested in reviewing your mortgage advertising that’s mailed to their homes.  It’s not that they are enticed by your low rate offers or your novel adjustable rate loan programs. Instead, they are awaiting your mailer because they want to find TILA and Regulation Z and MAP Act errors, missing or improper disclosures and anything in your ad that they can conclude constitutes an unfair or deceptive or abusive act or practice.

Here’s what you might see when you get an investigative demand about your advertising. They will ask you a bunch of questions.about how many versions of the ad did you send out? How many people responded to the advertisement?  Who reviewed the advertisement for compliance with all the rules before it went out?

If your ad makes certain statements that need to be verified as being accurate, the regulator will ask you to do that and provide evidence of how you substantiated each of your claims in the ad.

Lastly, the regulator will ask you to verify and explain and provide all documents that you used to verify that the rates and payments you included in your advertisement are accurate.

It’s good to know what to expect from your regulators before you send out new ads in the future..  Make sure you know all of the rules in your state and the disclosures required by law and that you are having your ads reviewed by an attorney or experienced compliance officer before you send them out.

 

 


New Format at Advertiseyourloans.com Posts and Pages

At Advertiseyourloans.com our goal is to provide you with a resource to look up tips and best practices examples of how to do certain types of advertisements for mortgages and other loan products.  To create uniformity among the information, tips, and sample disclosures that we provide you at our website we will be implementing a new format to present our content to you in an easy to understanding process.

The new AYL format will generaly follow the below outline and presentation. Some variation will occur where we want to proide more specialized information or tips related to specific advertising topics of interest. The format of our posts and pages will be as shown below:

Advertising Topic

  • Type of Advertisement:
  • Applicable Regulations
  • Disclosure Sample :
  • Practice Tip:
  • Tips and Traps:

 

Stay Tuned for new posts and advertising disclosure samples in this format.

 

– The Team – Advertiseyourloans.com