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Compliance Disclaimer

At The Vault Marketing, we design our materials with guidance for compliance with relevant federal regulations, including the Truth in Lending Act (TILA), the Real Estate Settlement Procedures Act (RESPA), and the Fair Housing Act. While we strive to provide a foundational compliance framework, full legal compliance is ultimately the responsibility of each subscriber.

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TILA Compliance: Trigger Terms and APR Disclosure

Under TILA (15 U.S.C. § 1601 et seq.), using specific terms, such as interest rate, monthly payment, down payment, or other financing details, may trigger the need to disclose the Annual Percentage Rate (APR) prominently. For example, the following “trigger words” typically require APR disclosure:

  • Interest rate (e.g., "1.5% interest rate")

  • Monthly payment (e.g., "Only $1,500 per month")

  • Down payment amount (e.g., "Low down payment of $5,000")

  • Term of repayment (e.g., "30-year mortgage")

  • Finance charges (e.g., "Only $2,000 in fees")

  • No closing costs

Whenever these terms appear, subscribers are responsible for adding the current APR to ensure TILA compliance. For more on TILA requirements, visit 12 CFR Part 1026.

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RESPA Compliance: Transparency in Settlement Costs

RESPA (12 U.S.C. § 2601 et seq.) mandates transparency around settlement costs and restricts certain practices, like kickbacks, in real estate transactions. While RESPA does not specifically address Equal Housing Opportunity logos, maintaining fair and clear disclosure practices is essential. For more on RESPA, see 24 CFR Part 1024.

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Fair Housing Act Compliance: Equal Housing Opportunity Logo

Under the Fair Housing Act, all marketing materials related to residential real estate transactions must display the Equal Housing Opportunity logo. This inclusion promotes fair lending and adherence to federal fair housing laws. For more on these requirements, visit 24 CFR Part 109.

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Your Responsibility

The Vault Marketing offers compliance guidance by providing templated statements and framework logos for each marketing material. However, subscribers must customize these materials to reflect current pricing, costs, and specific terms. As licensed Mortgage Loan Originators, subscribers are responsible for full legal compliance, including reviewing all materials, updating relevant disclosures, and consulting with a compliance professional when necessary.

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