A mortgage broker's website states 'Qualified borrowers can get loans with down payments as low as 3%.' Which statement about TILA advertising requirements is correct?
Correct Answer
B) This is permissible general advertising that doesn't trigger specific disclosure requirements
Under TILA Regulation Z Section 1026.24, stating a down payment amount or percentage is not a triggering term that requires additional disclosures. This is considered general promotional language that doesn't trigger the specific disclosure requirements for credit terms.
Why This Is the Correct Answer
Under TILA Regulation Z Section 1026.24, stating a down payment amount or percentage is not a triggering term that requires additional disclosures. This is considered general promotional language that doesn't trigger the specific disclosure requirements for credit terms.
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A borrower's PMI was scheduled for automatic termination on the loan's 15th anniversary (midpoint of 30-year term). However, the servicer failed to terminate the PMI and continued collecting premiums for 8 additional months. What must the servicer do?
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A borrower mentions they will be receiving a large inheritance of $75,000 next month to help with the down payment, but they cannot provide documentation because 'the estate is still in probate.' This statement alone would most likely trigger which BSA/AML consideration?