The FTC has sent more than 200 warning letters about ads that may be deceptive or violate TILA. The FTC statement gives the following examples of some of the ads the FTC discovered:
[S]ome ads touted rates as low as “1%” but failed to disclose adequately:
- that the stated rate was a “payment rate” – not the interest rate – that applied only during the loan’s initial period;
- that low advertised payments applied for only a short period; and
- the loan’s Annual Percentage Rate, the uniform measure of the cost of credit that enables consumers to shop for and compare mortgage offerings.
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