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In a mortgage origination file, an ad shows an interest rate but omits the APR presentation. Which action should be taken?

Correct Answer

B) State the rate as an annual percentage rate

Lines 261-265 and 273-277; 12 CFR 1026.24(c). Closed-end credit advertising rules require the finance charge rate to be stated as an annual percentage rate. Therefore, the correct response is "State the rate as an annual percentage rate".

Answer Options
A
Treat the compliance requirement as optional because closing is near.
B
State the rate as an annual percentage rate
C
Continue processing without correcting the disclosure, licensing, compensation, or consumer-protection issue.
D
Ignore the issue if the borrower orally agrees to continue.

Why This Is the Correct Answer

The correct response is "State the rate as an annual percentage rate". Closed-end credit advertising rules require the finance charge rate to be stated as an annual percentage rate.

Why the Other Options Are Wrong

Option A: Treat the compliance requirement as optional because closing is near.

Treat the compliance requirement as optional because closing is near. is not correct because the governing rule requires the compliant answer shown in the explanation.

Option C: Continue processing without correcting the disclosure, licensing, compensation, or consumer-protection issue.

Continue processing without correcting the disclosure, licensing, compensation, or consumer-protection issue. is not correct because the governing rule requires the compliant answer shown in the explanation.

Option D: Ignore the issue if the borrower orally agrees to continue.

Ignore the issue if the borrower orally agrees to continue. is not correct because the governing rule requires the compliant answer shown in the explanation.

Memory Technique

When an ad mentions a rate, look for APR.

Exam Tip

When an ad mentions a rate, look for APR.

Common Mistakes to Avoid

  • -The note rate and the APR are not interchangeable advertising disclosures.
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