FORUM PROFILE

Teaser / Introductory Rates – UDAAP

Home Forums Compliance Masters Group (Members Only) Teaser / Introductory Rates – UDAAP

Viewing 2 posts - 1 through 2 (of 2 total)
  • Author
    Posts
  • #2455
    KCapps
    Participant

    My marketing department is considering a promotion for a HELOC’s with an inroductary (“teaser rate”) (yikes) of 1.80% for the first 7 months; then it would convert to our fixed rate pricing as low as 4.00%, based on our current pricing model which is based on credit score. We will also be offering a lower fixed rate closed end HE as low as 4.55%. I have some others concerns that this may pose but one in particular is that of UDAAP. Am I off base in thinking that on the surface anyone would think that low (teaser rate) is the best way to go especially since the fixed rate portion is potentially less than the closed end HE? Could this be seen as unfair and deceptive?

    Any thoughts or feedback would be most appreciated.

    #2772
    jholzknecht
    Keymaster

    I don’t see any UDAAP issues with the pricing on these two products. What do the rest of you think?

Viewing 2 posts - 1 through 2 (of 2 total)
  • You must be logged in to reply to this topic.