We recently learned that Georgia has a special rule related to references to another lender’s name in your ads. In this case however, there was no mention of a prior lender, but instead the ad referred to the borrower’s current loan of $230,000 which is available from public records.
What was the violation?’
It turns out that if you reference the existing loan amount of the consumer, that is a trigger of specific disclosure rules where you must say the name of the prior lender and you must add a clear and conspicuous statement in the ad that your company is not affiliated with the existing lender.
Recommendation – don’t include the consumer’s current loan amount in your ads sent to Georgia customers – if you do so you will have to comply with the above requirements.