In a file escalation meeting, an audit analyst sees facts tied to Advertising Compliance Requirements. What should the file reflect?
Correct Answer
C) Substantiate advertised terms before publication
Why this is correct: Mortgage advertising compliance, governed by TILA/Regulation Z, requires that all advertised terms are accurate and not misleading. A key requirement is that the advertiser must have a reasonable basis or be able to substantiate the advertised terms (like rates or payments) before the advertisement is published. Therefore, the file should reflect that this substantiation was done prior to publication. Why the other choices are wrong: "Continue the activity because the borrower appears willing to proceed" is wrong because advertising rules apply to the publication of terms, not borrower transactions, and willingness does not excuse unsubstantiated claims. "Ignore the consumer-protection issue unless the borrower complains" is wrong because advertising compliance is a pre-publication duty, not triggered by complaints. "Document the issue later instead of correcting the compliance problem first" is wrong because an unsubstantiated advertisement must be corrected (i.e., substantiated) before it runs; documenting the lack of substantiation later is non-compliant. Exam tip: For advertising, remember the "substantiation" requirement. You must be able to support the advertised terms before you advertise them.
Why This Is the Correct Answer
The correct response is "Substantiate advertised terms before publication" because Mortgage advertising must avoid misleading claims and satisfy APR/trigger-term rules.
Why the Other Options Are Wrong
Option A: Continue the activity because the borrower appears willing to proceed.
Continue the activity because the borrower appears willing to proceed. is not correct because it does not apply the rule tested by this file scenario.
Option B: Ignore the consumer-protection issue unless the borrower complains.
Ignore the consumer-protection issue unless the borrower complains. is not correct because it does not apply the rule tested by this file scenario.
Option D: Document the issue later instead of correcting the compliance problem first.
Document the issue later instead of correcting the compliance problem first. is not correct because it does not apply the rule tested by this file scenario.
Memory Technique
mortgage advertising compliance: identify the rule being tested, then choose the action that documents or applies that rule before the file moves forward.
Exam Tip
Match the file facts to mortgage advertising compliance; do not choose an exception or shortcut that skips the required rule.
Common Mistakes to Avoid
- -Choosing an internal exception instead of the governing rule
- -Treating preliminary or informal facts as a substitute for required documentation
- -Answering from a familiar but unrelated mortgage topic
More Ethics & Fraud Questions
In a closing-readiness check, a disclosure specialist sees facts tied to Appraisal Fraud Detection. What should the file reflect?
An MLO recommends a loan with a low initial payment that will increase sharply in two years. The borrower says retirement income will be fixed and asks whether the payment can change. What is the appropriate response?
An MLO alters a bank statement to make the applicant's account balance appear higher and submits it to underwriting. Which response is appropriate?
A branch manager asks about a loan file because marketing proposes a rate the company is not prepared to offer. What should happen?
A branch pays its originators 1.1% of the loan amount on every file, and an extra $400 whenever the loan closes with an escrow waiver. Escrow waivers at this branch are granted only on loans priced above par, and the originator decides whether to offer one. Under Regulation Z, which part of this compensation arrangement, if any, is prohibited?
A borrower wants cash for necessary home repairs. A proposed refinance provides $15,000 cash but adds $12,000 in costs and extends repayment by 15 years. What is the best next step for the MLO?
A borrower pays a mortgage broker $3,400 directly at closing. The lender also offers the same brokerage 1.5% of the loan amount as a lender-paid credit on the same file. Under Regulation Z's dual-compensation rule, may the brokerage accept both payments on this transaction?
Before closing, the team discovers that an ad shows an interest rate but omits the APR presentation. What is the safest compliant answer?
A residential mortgage lender files a suspicious activity report about a borrower on 8 April. On 15 April the borrower calls to ask why the file has stalled, and the branch manager wants to tell him a report was filed so he can explain himself. May the manager tell the borrower that a suspicious activity report was filed?
The loan team is resolving Privacy and Confidentiality during a quality-control sample. Which action best fits the rule?
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