WAC 208-620-630
What are the advertising restrictions,
and what are some examples of those restrictions? (1)
Licensees are prohibited from advertising with envelopes or
stationery that contain an official-looking emblem designed to
resemble a government mailing or that suggest an affiliation
that does not exist. What are some examples of emblems or
government-like names, language, or nonexistent affiliations
that will violate the state and federal advertising laws?
Some examples include, but are not limited to:
(a) Characterizing products as "government loan
programs," "government-supported loans," or other words that
may mislead a consumer into believing that the government is
guaranteeing, endorsing, or supporting the advertised loan
product. Using the words "FHA loan," "VA loan," or words for
other products that are in fact endorsed or sponsored by a
federal, state, or local government entity is allowed.
(b) An official-looking emblem such as an eagle, the
Statue of Liberty, or a crest or seal that resembles one used
by any state or federal government agency.
(c) Envelopes designed to resemble official government
mailings, such as IRS or U.S. Treasury envelopes, or other
government mailers.
(d) Warnings or notices citing government codes or form
numbers not required by the U.S. Postmaster to be shown on the
mailing.
(e) The use of the term "official business," or similar
language implying official or government business, without
also including the name of the sender.
(f) Any suggestion or representation that the solicitor
is affiliated with any agency, bank, or other entity that it
does not actually represent.
(2) When I am advertising interest rates, the act
requires me to conspicuously disclose the annual percentage
rate (APR) implied by the rate of interest. What does it mean
to "conspicuously" disclose the APR? The type size of the APR
must be the same size or larger than any other rates stated in
the advertisement.
(3) The act prohibits me from advertising an interest
rate unless that rate is actually available at the time of the
advertisement. How may I establish that an advertised
interest rate was "actually available" at the time it was
advertised? Whenever a specific interest rate is advertised,
the licensee must retain a copy of supporting rate
information, and the APR calculation for the advertised
interest rate.
(4) Must I quote the annual percentage rate when
discussing rates with a borrower? Yes. You must quote the
annual percentage rate and other terms of the loan if you give
an oral quote of an interest rate to the borrower. TILA's
Regulation Z, 12 CFR, part 226.26 provides guidance for using
the annual percentage rate in oral disclosures.
(5) May a licensee advertise rates or fees as the
"lowest" or "best"? No. Rates described as "lowest," "best,"
or other similar words cannot be proven to be actually
available at the time they are advertised. Therefore, they
are a false or deceptive statement or representation
prohibited by RCW 19.146.0201(7).
(6) May I solicit using advertising that suggests or
represents that I am affiliated with a state or federal
agency, municipality, federally insured financial institution,
trust company, building and loan association, when I am not;
or that I am an entity other than who I am? No. It is an
unfair and deceptive act or practice and a violation of the
act for you to suggest or represent that you are affiliated
with a state or federal agency, municipality, federally
insured financial institution, trust company, building and
loan association, or other entity you do not actually
represent; or to suggest or represent that you are any entity
other than who you are.
(7) If I advertise using a borrower's current loan
information, what must I disclose about that information?
When an advertisement includes information about a borrower's
current loan that you did not obtain from a solicitation,
application, or loan, you must provide the borrower with the
name of the source of the information.
[Statutory Authority: RCW 43.320.040. 08-15-125, §
208-620-630, filed 7/22/08, effective 8/22/08. Statutory
Authority: RCW 31.04.165, 31.04.015, 31.04.045, 31.04.075,
31.04.085, 31.04.093, 31.04.102, 31.04.115, 31.04.145,
31.04.155, and 31.04.175. 06-04-053, § 208-620-630, filed
1/27/06, effective 2/27/06.]