Advertising, Sponsorship and Marketing

Generation Lending Inc complies with both federal mortgage lending advertising requirements and specific laws and a regulation regarding advertising in the states where Generation Lending Inc does business. Advertising and marketing materials include any materials distributed, published or displayed by any means including print (such as mail, email, fax, newspapers, magazines or flyers), telephone scripts, television, radio, the Internet, and/or billboards. Liability for non-compliance exists under these laws. It is mandatory that any advertising done by Generation Lending Inc branch offices and/or loan originators comply with this policy. 

It is Generation Lending Inc’s policy that all advertising materials be truthful and nondeceptive, reasonable, nondiscriminatory and fair, and must include all appropriate required disclosures. Employees responsible for the creation and distribution of any advertising and marketing materials are required to comply with federal consumer protection laws, such as the Federal Mortgage Acts and Practices Advertising Rules (Regulation N), the Truth in Lending Act and Regulation Z, and fair lending laws and regulations, as well as agency regulations and state specific laws. 

It is a violation of this policy, and the aforementioned federal regulations, for any person to make any material misrepresentation regarding any term of any mortgage credit product, but not limited to, the following:

1. The interest charged for the mortgage product, including misrepresentations about the amount of interest owed each month that is included in the payment, loan amount or total amount due; or the interest owed each month that is not included in the payments but is instead added to the total amount due; 2. The variability of interest, payments or other terms of the mortgage product. 3. Any comparison between any actual or hypothetical rate or payment. 4. The annual percentage rate, simple annual rate, periodic rate, or any other rate. 5. The amount of fees to the consumer associated with the mortgage product, including misrepresentation that no fees are charged. 6. Loans with specified terms when no loan products with those terms are available. 7. The terms, amounts, payments or other requirements relating to taxes or insurance associated with the mortgage product. 8. The existence or amount of any penalty for making prepayments on the mortgage. 9. The existence, number, amount or timing of any minimum or required payment. 10. The lack of closing costs. 11. The effectiveness of the mortgage product in helping the consumer resolve difficulties in paying debts. 23 Rv. 05/27/2020 12. Savings available by refinancing. 13. The consumers ability to obtain any mortgage product or term whether the consumer has been preapproved or guaranteed for any such product; or 14. The consumer’s ability to obtain a refinance of any mortgage product whether, the consumer has been preapproved or guaranteed for any such refinance.

1. Oral or written statements that would discourage on a prohibited basis a reasonable person from making or pursuing an application.

2. Words, symbols, models or other forms of communication that express, imply, or suggest a discriminatory preference or a policy of exclusion in violation of the ECOA.

3. The FHA logo or HUD seal, however you may use the FHA Approved Lending Institution seal followed by the statement ‘Lender is not acting on the behalf of or at the discretion of the HUD/FHA or Federal Government’; or

4. The words “federal”, “government”, national”, US Department of Housing and Urban Development”, “Federal Housing Administration” and/or the letters “HUD” or “FHA”, unless advertising an FHA product.

5. Any advertisement that states the licensee can arrange “low doc/no doc, no income/no asset, stated income, stated asset, no ratio”, or similar loan products must contain a statement that these products may have a higher interest rate, more points or more fees than other products that require documentation. 

Below are general advertising requirements applicable in most states: 1. A licensee may not advertise, print, display, publish, distribute, broadcast or televise, in any manner, a statement or representation with regard to rates, terms or conditions for a mortgage loan that is false, misleading or deceptive. 2. A licensee may not, in connection with a mortgage loan transaction solicit, advertise or enter in to a contract for specific interest rates, points, or other financing terms unless the terms are actually available at the time of soliciting, advertising or contracting from a lender with whom the mortgage loan originator maintains a written correspondent or loan agreement. 3. A licensee shall not advertise any rate of interest without conspicuously disclosing the annual percentage rate implied by such rate of interest. 4. 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. 5. Advertising that a specific interest rate, points or financial terms are available when the rates, points or financial terms are not actually available is a misleading or deceptive communication. 6. A licensee shall not use or cause to be published any advertisement that contains 24 Rv. 05/27/2020 false, misleading or deceptive statement or representation, or identifies the licensee by any name other than the name listed on the license issued. 7. The individual Unique Identifier number of the Mortgage Loan Originator and the company Unique Identifier shall be clearly shown on all residential mortgage loan application forms and in any printed, published, e-mailed or internet solicitations or advertisements, including business cards and internet websites. The Unique Identifier shall not be smaller than 8-point bold font All advertising must be approved in advance by Generation Lending Inc Senior Management. Any unauthorized advertising may be cause for dismissal. This includes any and all forms of print, radio, television or billboards.

A copy of all advertising must be forwarded to Senior Management for prior approval. Generation Lending Inc Unique Identifier will accompany all written or audio advertising.

•If an interest rate is being quoted, the APR must also be quoted in the same size font as the interest rate.

•Ads must read Generation Lending Inc.

•All phone greetings and voicemails are to feature Generation Lending Inc. •Use of Equal Housing Lender Symbol will be used on all advertising. 

Generation Lending Inc’s policy is to retain all closed loan applications for a minimum of 5 years. Generation Lending Inc’s policy is to retain all denied and withdrawn loans for a minimum of 25 months from the date of denial or withdraw. Generation Lending Inc’s policy is to retain all advertising for a minimum of 5 years.