Under TILA's advertising rules (Regulation Z), general statements such as "Come in today for your free consultation" do not trigger the requirement for additional disclosures. This type of advertisement does not include specific loan terms like payment amounts, interest rates, or other terms that would require further explanation.
* Advertisements with terms like "Payments as low as $600" (A) or "1 point up front" (B) are triggering terms under TILA and would require additional disclosures about the APR, loan term, and other conditions.
References:
* Truth in Lending Act (TILA), 12 CFR Part 1026 (Regulation Z)
* CFPB Advertising Guidelines on TILA

To qualify as a Safe Harbor Qualified Mortgage (QM), the APR must be less than 1.5% above the Average Prime Offer Rate (APOR) for first-lien loans. This threshold is set by the Qualified Mortgage Rule under the Dodd-Frank Act to ensure that Safe Harbor QMs offer fair and affordable loan terms, protecting borrowers from predatory lending practices.
* Safe Harbor QMs are considered the most consumer-friendly loans and are protected from liability under the Ability-to-Repay Rule (ATR).
References:
* Dodd-Frank Act, Qualified Mortgage Rule
* CFPB Ability-to-Repay and Qualified Mortgage Standards

Under Truth in Lending Act (TILA) Regulation Z, a finance charge is defined as the cost of consumer credit as a dollar amount, including any charges payable directly or indirectly by the consumer and imposed as a condition of or an incident to the extension of credit. Discount points are a form of prepaid interest paid at closing to lower the interest rate, and are always considered a finance charge.
"Finance charges include interest, points, and other costs payable by the consumer at closing, such as loan fees and certain mortgage broker fees. Charges such as appraisal fees, title insurance, and pest inspection fees are typically not finance charges if not required by the creditor."
- 12 CFR § 1026.4(a); TILA/Regulation Z Commentary
References:
CFPB, What is a finance charge?
12 CFR § 1026.4(a), Regulation Z

When responding to a state regulator's request regarding a consumer complaint, the company should provide all requested documents, along with an explanation of the facts and what caused the complaint. Regulators have authority to access unredacted information as part of their oversight and investigative powers.
"Regulators have the right to access all pertinent documentation in the course of investigations or examinations. Companies should provide a full and factual response, including all supporting documentation and their explanation of events."
- SAFE Act, 12 U.S.C. § 5117; NMLS Policy Guidebook
References:
SAFE Act, 12 U.S.C. § 5117
NMLS, Investigation & Enforcement

An assumable loan is a loan in which a purchaser of a property has the option to take over the existing loan payments under the same terms as the original borrower. This can happen with certain types of loans, such as FHA or VA loans, which allow the buyer to assume the mortgage, potentially at a more favorable interest rate than current market rates.
* Options like taking out a second mortgage (A), choosing a loan servicer (B), or selling the loan (D) do not describe assumable loans.
References:
FHA Guidelines on Assumable Loans
VA Loan Assumption Guidelines