10-1 ARM Loan with Disclosures – What’s Wrong with this Ad?
![IMG_0052[1]](https://c749c6.p3cdn1.secureserver.net/wp-content/uploads/2014/10/IMG_00521.jpg)
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 …