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Ethics & Fraudeasy18% of exam

A branch manager asks about a loan file because an ad shows an interest rate but omits the APR presentation. What should happen?

Correct Answer

C) State the rate as an annual percentage rate

Why this is correct: The governing concept is Regulation Z's closed-end credit advertising rule (the governing federal rule When an advertisement mentions an interest rate, it must also disclose the Annual Percentage Rate (APR). The APR is a more comprehensive measure of credit cost. The proper action is to ensure the ad states the rate as an APR. Why the other choices are wrong: "Ignore the advertising and consumer protection issue unless the borrower complains" is wrong because the MLO has a duty to provide accurate disclosures proactively. "Use borrower consent as a substitute for the governing mortgage rule" is wrong because legal requirements cannot be waived by the borrower. "Wait until after the risk-control meeting to decide whether the disclosure, filing, or license issue matters" is wrong because advertising disclosures are required at the time of the ad; delaying the decision is non-compliant. Exam tip: Advertising rules are triggered by the content of the ad itself, not by borrower action or complaint.

Answer Options
A
Ignore the advertising and consumer protection issue unless the borrower complains.
B
Use borrower consent as a substitute for the governing mortgage rule.
C
State the rate as an annual percentage rate
D
Wait until after the risk-control meeting to decide whether the disclosure, filing, or license issue matters.

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: Ignore the advertising and consumer protection issue unless the borrower complains.

Ignore the advertising and consumer protection issue unless the borrower complains. is not correct because it bypasses the rule supported by the explanation.

Option B: Use borrower consent as a substitute for the governing mortgage rule.

Use borrower consent as a substitute for the governing mortgage rule. is not correct because it bypasses the rule supported by the explanation.

Option D: Wait until after the risk-control meeting to decide whether the disclosure, filing, or license issue matters.

Wait until after the risk-control meeting to decide whether the disclosure, filing, or license issue matters. is not correct because it bypasses the rule supported by 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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