Suppose the bank was to run an advertisement that said they would meet any advertised RATE.
Then this scenario happens. A person brings in an ad from a competitor for a HELOC, it has a very low introductory rate, and then after a few months changes to a new rate and is a variable rate HELOC after that.
IF the bank does not have a variable rate HELOC with an introductory time period for a teaser rate is there a problem telling the potential borrower that, and then discussing other available products?
If you advertise that you match any rate, then you better match the rate or you are risking a UDAAP problem. If your offer has restrictions, then the restrictions should be disclosed in the advertisements.