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My marketing department is considering a promotion for a HELOC’s with an inroductary (“teaser rate”) (yikes) of 1.80% for the first 7 months; then it would convert to our fixed rate pricing as low as 4.00%, based on our current pricing model which is based on credit score. We will also be offering a lower fixed rate closed end HE as low as 4.55%. I have some others concerns that this may pose but one in particular is that of UDAAP. Am I off base in thinking that on the surface anyone would think that low (teaser rate) is the best way to go especially since the fixed rate portion is potentially less than the closed end HE? Could this be seen as unfair and deceptive?
Any thoughts or feedback would be most appreciated.
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