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An online mortgage advertisement displays 'Refinance today! 3.5% rate available.' Under TILA, what makes this advertisement potentially non-compliant?

Correct Answer

C) The rate appears to be the APR but doesn't include the phrase 'annual percentage rate'

Under TILA Regulation Z Section 1026.24(f), if an advertisement states a rate of finance charge, it must state the rate as an 'annual percentage rate' using that term or the abbreviation 'APR.' Simply stating '3.5% rate' without clarification violates this requirement.

Answer Options
A
The rate is stated as an annual percentage rate when it's actually a simple interest rate
B
The advertisement doesn't specify the loan term
C
The rate appears to be the APR but doesn't include the phrase 'annual percentage rate'
D
The advertisement doesn't include closing costs

Why This Is the Correct Answer

Under TILA Regulation Z Section 1026.24(f), if an advertisement states a rate of finance charge, it must state the rate as an 'annual percentage rate' using that term or the abbreviation 'APR.' Simply stating '3.5% rate' without clarification violates this requirement.

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