Internet Advertising Banner Ads and Rate Tables – How to Do it Right

Be careful with Internet ads for mortgages. It’s a competitive market out there to generate mortgage leads on the Internet and not everyone out there is playing by the same rules. This is a matter of fairly and openly advertising your mortgage products and services.

What rules do you need to follow for advertising mortgage loans on the Internet?

1) only advertise rates that are actually available
2) use an “as of” date in your ad to show the date that the rate is available
3) you can add disclosures to your ad on the landing page (of a banner ad for example) or at a linked page. Make all important disclosures just a click away so you can show that consumers could easily find any important disclosure language that explains your offer or is otherwise required.
4) advertise rates that a substantial number of your typical customers will qualify for such rate

What happens when these rules are not followed? This came up in the CFPB enforcement that was announced earlier this year against Amerisave.

What did Amerisave do wrong?

On its own website, its banner ads, and its listings on a third party’s rate table site, Amerisave advertised misleading interest rates for its mortgage products. These rates were not available when advertised and the rates were lower than the typical Amerisave customer were likely to lock.

What did Amerisave pay to resolve this matter?

There was a few other alleged unlawful practices that were part of Amerisave’s consent order but the total payout was 19.3 Milllion.