Advertising ARM rates

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March 15, 2016 at 8:54 am EDT #8911

Kristin
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When advertising rates for an ARM loan, must we disclose that the payment may increase (in those or similar words) or are we only required to disclose that the interest rate may increase? The advertisement will show rates for an ARM product as well as two fixed rate products, but only use the word “fixed” to describe the two actual fixed rate products.
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March 16, 2016 at 11:28 am EDT #8922

rcooper
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The disclosure of the APR alone wouldn’t trigger a statement about the payment. However you may have other information in your advertisement that would require more detail. You should review 1026.24(f) and its commentary.
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