Reverse Mortgage AdvertisingBackward Mortgage Advertising
Decree N forbids a lender from misrepresenting himself, either explicitly or implicitly, in the advertising of a mortgage credit. Until recently, it was generally assumed that you had not infringed Ordinance No 2 as long as you had not made an incorrect statement in an ad. For example, if you levied a two per cent lending rate and your ad did not give details of the rates to which you were entitled.
Obviously, you could not indicate in the ad that there were no credit charges if you had charged a charge. Well, the issue now is how included is the concept of implications. In a recent news letter, I wrote that the Consumer Financial Protection Bureau (CFPB) imposed a fine on three reverse mortgage creditors for declaring in their ads that the lender could not loose his home, although if the lender did not cover land tax, did not insure the home, or breached another contract in the mortgage contract, the lender could loose the home.
Specifically, by saying that the debtor could not loose his home, the advertiser indicated that the debtor had no other pecuniary obligation in relation to the ownership of the credit agreement. Let us now suppose you make a comment in your ad about what the montly mortgage will be.
Is your testimony about the montly payments implicitly a wrong representation? Let us assume that the credit agreement has a very high or very long advance deposit fine. However, the issue is that no one other than CFPB knows how far the idea of mortgage advertising implications will take it. Right now, I am encouraging the comply people who are responsible for the advertising check to familiarize themselves with Regulation N and make sure that everything that is said in your ads is correct and that there is nothing that means something that is wrong.
In the future, its three main priority areas will be redelining, mortgage and credit management for students, and microcredit in relation to minorities and women's enterprises. It is important because it is the best way to demonstrate that the bank is able to reach all companies in its field.