What advertising disclosures are required under TILA-RESPA and Regulation Z?

• A. Clear and conspicuous disclosure of the annual percentage rate; avoid misleading terms; if a rate is advertised, the terms must be accurate and any adjustments or variable rates disclosed.
• B. APR disclosure is optional and not required for advertised rates.
• C. Only disclosures about fees are required; APR not required.
• D. Advertising disclosures require only that a rate be shown; terms do not need to be accurate.

Answer: (A)

When advertising mortgage terms, you must present the APR clearly and conspicuously and ensure the terms behind that rate are accurate. If a rate is advertised, any adjustments or variable-rate features must be disclosed so the borrower can compare offers accurately. This keeps promotions from being misleading by hiding costs or future rate changes. The other ideas—that the APR is optional, that only fees matter, or that a rate can be shown without accurate terms—don’t fit Regulation Z, which requires the APR and the material terms affecting cost to be disclosed whenever a rate is advertised.