Rocket Mortgage Settlement Agreement and Order

SETTLEMENT AGREEMENT AND

ORDER

ROCKET

MORTGAGE, LLC

The purpose of this Settlement Agreement and Order (“Agreement”) is to resolve

certain

disputes and require certain corrective

action in relation to issues noted in the

Non-Depository

Supervisory Committee’s (“NDSC”) 2018 inquiry into the

advertising practices of Quicken

Loans (n/k/a Rocket Mortgage,

LLC) (the

“Matter”). The

following terms are used in this

Agreement:

Company: Rocket Mortgage, LLC, formerly

known as

Quicken

Loans, LLC

Participating States:

Alabama State

Banking

Department;

Alaska

Division of Banking and

Securities;

District of Columbia

Department of Insurance, Securities,

and Banking;

Idaho Department of

Finance;

Illinois Department of

Financial

and Professional

Regulation;

Iowa

Division of

Banking; Mississippi

Department

Banking and Consumer Finance;

Ohio Department of Commerce;

Oklahoma

Department of Consumer

Credit; Tennessee Department of

Financial

Institutions;

Department

Savings & Mortgage

Lending (an

agency of the

State of Texas);

Washington Department of Financial

Institutions.

WHE

REAS, the Company is a Michigan limited liability company with a main office at

1050 Woodward Avenue, Detroit, Michigan; and

WHEREAS, the Company is licensed as a mortgage lender under the respective laws of

several states, including the Participating States; and

WHEREAS, the mortgage regulators of the Participating States (“State Regulators”) are

members of the Conference of State Bank Supervisors (“CSBS”) (exclusive of the Texas

Department of Savings & Mortgage Lending and the Oklahoma Department of Consumer

Credit). The Participating States (exclusive of the Illinois Department of Financial and

Professional Regulation) issued a Uniform Report of Investigation to the Company (“Report”),

dated September 12, 2019, which fully described its allegations as to the Company’s advertising

practices and its regulatory expectations with respect to those practices (the “Allegations”); and

WHEREAS, the State Regulators have agreed to address the Allegations and its

enforcement concerns with the Company in a collective and coordinated manner, working

through the NDSC. The State Regulators and the Company are collectively referred to herein as

the “Parties”; and

EREAS, the Company, by and through its representative, has consented to this

Agreement without admitting or denying any charges of noncompliance with any federal or state

advertising laws or other applicable laws; voluntarily agrees to waive any procedural rights as

they concern any aspect of this Agreement, except procedural rights created by or expressly

reserved in this Agreement; and represents that the person executing this Agreement on its behalf

is duly authorized to do so and legally bind the Company; and

WHEREAS, the Parties enter into this Agreement with the intention of resolving the

Matter, including the Allegations and assertions set forth in the Report; and

WHEREAS, except with regard to the enforcement of this Agreement, the Company’s

consent to the provisions of this Agreement does not bar, estop, waive, or otherwise prevent the

Company from raising any defenses to any action taken as a result of or outside this Agreement

by any federal or state agency or department, or any private action against the Company; and

WHEREAS, the Parties agree this Agreement is a public record that is a reportable event

for purposes of the regulatory disclosure questions on The Nationwide Multistate Licensing

System.

NOW, THEREFORE, the Participating States, acting under statutory authority and with

the non-objection of the Company, hereby order that the undersigned representative take, on

behalf of the Company, the following steps in furtherance of addressing the regulatory

expectations of the Participating States, clarifying regulatory standards in federal advertising

laws, and maintaining the highest standard of full disclosure for advertising compliance in the

mortgage industry.

ONETARY COSTS AND PENALTIES

thin thirty (30) days of the Effective Date, the Company shall pay to the Participating

States the sum of Five Hundred Thousand Dollars ($500,000) inclusive of investigative costs in

the amount of Fifty Thousand Dollars ($50,000) to the State of Washington. Payment shall be

made in the amounts and by the mechanisms instructed jointly by the Participating States in

writing within ten (10) days of the Effective Date.

The Company shall also be liable to the Participating States collectively for the additional

sum of up to One Million Dollars ($1,000,000), payable only in the event the Company does not

comply with Section III of this Agreement in the two (2) year period after the Effective Date and

only as otherwise permitted under this Agreement (“Stayed Penalty”). The amount of such

Stayed Penalty shall be reduced by One-Hundred and Twenty-Five Thousand Dollars

($125,000), and forgiven, for each Quarter (3 months) from the Effective Date of this Agreement

in which the Company complies with the terms of this Agreement. As further set forth in

Section IV, if any Participating State determines the Company is in material noncompliance with

the terms of this Agreement, that State may take any action to seek to lift the stay and enforce

that State’s equal share of the Stayed Penalty in effect at the time of the alleged noncompliance,

pursuant to any administrative or judicial process available under the laws of the Participating

State initiating the action.

II. REMEDIAL MEASURES

As a re

sult of the Report and based upon the Allegations, the Company has taken the

steps outlined in Section III below to more closely align its advertising and marketing practices

to regulatory expectations.

The Company has updated its Marketing Policy to reflect all updated advertising practices

and standards set forth in Section III. The Company will maintain and utilize such updated

advertising practices and standards unless and until changes in state or federal advertising laws

or guidance require further updates. Nothing in this Section will require the Company to

continue to use the specific advertising materials described in the Report or the specific

advertising materials provided by the Company to one or more of the Participating States as

examples of the updates to those materials.

The Company will continually monitor and update its advertising practices to comply with

all state and federal advertising laws.

III.

ADVERTISING UPDATE MEASURES

1) General Advertising Updates

Marketing collateral advertising discounted interest rates have been updated to

disclose clearly and conspicuously both the discount points associated with the

advertised interest rate and the dollar cost of those discount points.

Marketing collateral advertising mortgage rates or terms have been updated to

reformat the applicable disclosures, including appearing in the font, color, size, and

shade, in accordance with the format agreed upon between the Participating States

and the Company.

Marketing collateral advertising a new monthly payment that is calculated without

including taxes and insurance have been updated to place the required disclosure

under Regulation Z, 12 C.F.R. § 1026.24(f)(3)(i)-(ii), directly below or next to the

new monthly payment or include a conspicuous hyperlink directly below or next to

the new monthly payment that links directly to the required disclosure under

Regulation Z.

rect Mail Advertising Updates

Triggering term disclosures required under Regulation Z, 12 C.F.R. § 1026.24(d),

appearing on the reverse of direct mail solicitations for extending a firm offer of

credit have been updated to appear in the same font, color, size, and shade as the body

of the main text on the front of the solicitation.

Direct mail extending a firm offer of credit has been updated to state the recipient has

been “Pre-Selected” for the advertised offer.

Direct mail extending a firm offer of credit has been updated so the assumed gross

monthly income is based on the minimum income that would be eligible for the

advertised loan amount.

When advertising products with pricing impacted by a consumer’s debt-to-income

ratio (“DTI”), the Company updated its policy to apply the maximum price

adjustment for DTI to the advertised loan terms.

nternet Advertising Updates

The Company’s “Mortgage Rates” webpage has been updated to remove the

assumption that the pricing was generated based on a borrower having a DTI below

30 percent.

The Company’s “Mortgage Rates” webpage has been updated by placing a hyperlink

labeled “See Legal Disclosures” directly below the listed products and interest rates.

The hyperlink takes the consumer directly to the applicable product and rate

disclosures.

The Quicken Loans and Rocket Mortgage websites have been updated to remove any

reference to adjustable rate mortgages (“ARMs”) as a mortgage product with the

“lowest rate” or any similar reference.

The Company’s “Mortgage Rates” webpage language describing ARMs has been

updated to read “Adjustable rate mortgages (ARMs) may offer lower initial rates than

some other loan types. ARMs are a great option if you expect to sell your house or

refinance before the initial fixed-rate ends….”

4) Pop-Up Advertising Updates

The Company’s landing page on LowerMyBills.com has been updated to make

Regulation Z’s triggering term disclosure, 12 C.F.R. § 1026.24(d), appear so that a

consumer sees that disclosure immediately upon clicking on a pop-up advertisement.

LowerMyBills, a third-party lead generator, has updated the refinance payment

calculator on its website to display the annual percentage rate (APR) with equal

prominence to the advertised simple interest rate.

-Mail Advertising Updates

Emails advertising interest rates have been updated to include subscripts directing the

consumer to the applicable disclosures made clearly and conspicuously in accordance

with Regulation Z, 12 C.F.R. § 1026.24(e) and which subscripts the Company has

updated to reformat the applicable disclosures.

6) Sales Representative Scripting Updates

All sales scripts have been updated to remove any mention of an escrow refund or the

opportunity to skip a monthly payment as potential benefits of refinancing.

All sales scripts have been updated to remind sales representatives to quote an APR

and, where applicable, discount points and the dollar cost of those points, whenever

orally quoting a nominal interest rate.

All sales scripts have been updated to remove any mention of “wholesale.”

All sales scripts have been updated to ensure all representations are substantiated.

The Company has updated its Marketing Policy to outline the review process for sales

representative scripts and compliance guidelines for the content of the sales

representative scripts.

The foregoing updates have been incorporated into exemplar marketing templates attached

as Exhibits A, B, and C (“Updated Materials” or “Exemplars”); they either have been

implemented or will be implemented immediately upon entry of this Agreement; and the

Updated Materials shall be deemed hereafter to comply with this Agreement. Use of the

Updated Materials is in compliance with this Agreement.

Notwithstanding any prior claim or right of confidentiality, any Participating State may use

the Updated Materials as model materials and disclosures to provide guidance to others engaged

in advertising in the State.

IV.

USE

OF ADVERTISING MATERIAL INCONSISTENT WITH SECTION III

In the event of the Company’s use of advertising materials that are not consistent with the

substance of the standards in Section III, any State Regulator in whose State such materials are

used and that seeks a remedy for such noncompliance may issue a written notice of material

noncompliance to the Company (“Noncompliance Notice”).

1) To the extent the Noncompliance Notice reflects the Company’s attempted use of the

Updated Materials in compliance with Section III, the Company shall have the option

to cure the material noncompliance by implementing the Updated Materials accurately

as soon as reasonably practical to do so, but no later than 30 days after receipt of the

Noncompliance Notice.

2) To the extent the Noncompliance Notice concerns the Company’s use of any other

advertising materials that are not consistent with the substance of the standards in

Section III, or if the Company does not opt to implement the Updated Materials under

subpart 1, the Company and the State Regulator(s) shall have twenty (20) days after the

Company’s receipt of the Noncompliance Notice to confer regarding the allegation of

noncompliance. If, and to the extent, after conferral, the State Regulator(s) maintain

that there is a material noncompliance with Section III, the State Regulator(s) shall

confirm the noncompliance to the Company in writing and the Company thereafter will

be given fifteen (15) days, unless otherwise agreed, to cure the alleged material

noncompliance.

If the Company timely cures under either subpart 1 or 2 above, that shall be deemed to

resolve the alleged violation and the State shall have no right to obtain any order or pursue any

remedy based on the violations cited in the Noncompliance Notice. If the Company fails to cure

the noncompliance within the applicable timeframe, the State Regulator may take such action

against the Company to seek the Stayed Penalty available to that State under Section I for the

violations cited in the Noncompliance Notice as authorized under applicable law. Each

Participating State agrees to be limited to recovering only that State’s equal share of the Stayed

Penalty in effect at the time of the alleged noncompliance with this Agreement, and it cannot

seek any additional penalty, order or remedy for the violations cited in the Noncompliance

Notice, including an order compelling compliance with this Agreement or a cease and desist

order or any action against the Company’s license, and it shall not cite such noncompliance or

payment of the Stayed Penalty as facts and circumstances that constitute an independent

violation of law or grounds for action by the State Regulator.

The cure periods set forth in this Section IV shall not apply to violations of the standards

set forth in Section III that occur more than twice in any rolling six month period during the term

of the Agreement.

The Company shall not be deemed to have waived any defenses as a result of this Section

or Section I.

V. ADDITIONAL TERMS APPLICABLE TO THE UPDATED MATERIALS

In addition to the other terms of this Agreement, the Updated Materials are governed by the

terms of this Section V.

1) Attached as Exhibit A is the exemplar marketing template for direct mail advertising,

including firm offers of credit (“Direct Mail Exemplar”), which the Parties agree is

consistent with marketing standards set out in Regulation Z, the MAP Rule, and other

applicable federal and State law. Specifically, the Direct Mail Exemplar provides a

“clear and conspicuous” disclosure resulting from triggering terms under Regulation Z,

12 C.F.R. §§ 1026.24(b), (d), by providing the disclosure of such terms in the same font,

color, size, and shade as the substance of the marketing asset and segregated from other

disclosures not related to the pricing of the loan. The Direct Mail Exemplar also

provides, consistent with the MAP Rule, 12 C.F.R. §§ 1014.3(b), (c), that where

advertising a discounted interest rate, the advertisement discloses the cost, reflected as a

dollar amount, to be paid to achieve the discount. The Direct Mail Exemplar also

complies with the requirement of Washington law as to the disclosure of discounts and

discount points. WASH. ADMIN. CODE § 208-620-630(9). See also id. § 208-660-

500(3)(l).

2) Attached as Exhibit B is the exemplar marketing template for email advertising (“Email

Exemplar”), which the Parties agree is consistent with the marketing standards set out in

Regulation Z, the MAP Rule, and other applicable federal and State law. Specifically,

the Email Exemplar provides a “clear and conspicuous” disclosure resulting from

triggering terms under Regulation Z, 12 C.F.R. §§ 1026.24(b), (d), by including a

subscript next to the trigger term for each advertised product directing the consumer to

the applicable disclosure and providing such disclosures in the same font, color, size, and

shade as the substance of the marketing asset. The Email Exemplar also provides,

consistent with the MAP Rule, 12 C.F.R. §§ 1014.3(b), (c), that where advertising a

discounted interest rate, the advertisement discloses the cost, reflected as a dollar amount,

to be paid to achieve the discount. The Email Exemplar also complies with the

requirement of Washington law as to the disclosure of discounts and discount points.

WASH. ADMIN. CODE § 208-620-630(9). See also id. § 208-660-500(3)(l).

3) At

tached as Exhibit C is the exemplar marketing template for advertising rates on a

website (“Website Exemplar”), which the Parties agree is consistent with marketing

standards set out in Regulation Z, the MAP Rule, and other applicable federal and State

law. Specifically, the Website Exemplar provides a “clear and conspicuous” disclosure

resulting from triggering terms under Regulation Z, 12 C.F.R. §§ 1026.24(b), (d), (e) by

making the disclosure one-click away placing a hyperlink labeled “*Legal Disclosure”

directly below the trigger term that displays the applicable disclosure of such terms in the

same font, color, size, and shade as the terms triggering the disclosure. The Website

Exemplar also provides, consistent with the MAP Rule, 12 C.F.R. §§ 1014.3(b), (c), that

where a website advertises a discounted interest rate, the advertisement discloses the cost,

reflected as a dollar amount, to be paid to achieve the discount. The Website Exemplar

also complies with the requirement of Washington law as to the disclosure of discounts

and discount points. WASH. ADMIN. CODE § 208-620-630(9). See also id. § 208-660-

500(3)(l).

The Company shall not be required to use any or all of the Exemplars if its advertising

materials otherwise comply with this Agreement, but if it uses any Exemplar or one materially

similar, the advertising shall be deemed to comply with this Agreement, Regulation Z, the MAP

Rule, and other applicable federal and State law with respect to the material disclosed in the

Exemplar.

VI.

ENERAL

PROVISIONS

1) J

urisdiction: Pursuant to the licensing and supervision laws of the Participating States, the

Participating States have jurisdiction over the Company as described herein and may enforce

the terms of this Agreement in any such Participating State unless otherwise stated in this

Agreement.

2) Binding Nature: The terms of this Agreement shall be legally binding upon and benefit the

Company’s officers, owners, directors, employees, successors (including any duly licensed

successor licensee), and assigns.

3) Standing and Choice of Law: Each State Regulator has standing to enforce this Agreement

in the judicial or administrative process otherwise authorized under the laws and regulations

of the corresponding Participating States. Upon entry, this Agreement shall be deemed a

final order of each respective State Regulator unless adoption of a subsequent agreement is

necessary under the terms of the corresponding Participating State. In the event of any

disagreement between any State Regulator and the Company regarding the enforceability or

interpretation of this Agreement and compliance therewith, the courts or administrative

agency authorized under the laws of the respective Participating State shall have exclusive

jurisdiction over the disputes, and the laws of such State shall govern the interpretation,

construction, and enforceability of this Agreement.

4) Titles: The titles used to identify the paragraphs of this Agreement are for the convenience of

reference only and do not control the interpretation of this Agreement.

Counterparts: This Agreement may be executed in separate counterparts, including

electronically by e-mail of a .pdf or similar file, each of which shall be deemed to be an

original, but all of which, taken together shall constitute one and the same Agreement. A

copy of the signed Agreement shall be given the same effect as the originally signed

Agreement.

6) Final Agreement: This Agreement supersedes any prior oral or written discussion or

agreement related to the Matter and constitutes the entire agreement between the Parties

relating to the Matter. Upon issuance of this Agreement by each State Regulator, this Matter

will be resolved with the respective State Regulator and such State Regulator will not take

any future enforcement or other action against the Company based upon the Allegations of

the Report. Each Participating State shall close, with no further findings, the examination

that resulted in the issuance of the Report.

Issuance of this Agreement is without prejudice to the right of a State Regulator to take

enforcement action against the Company based upon a violation of this Agreement or the

matters underlying its entry, if a State Regulator determines that any representation made by

the Company and reflected herein is subsequently discovered to be untrue. Nothing in this

Agreement shall be construed as limiting a State Regulator’s ability to take enforcement

action against the Company based upon evidence indicating that the Company withheld

material information from or made any material misstatement or omission to a State

Regulator in connection with this Matter.

7) Enforcement: No Restriction on Existing Examination and Investigation Authority: This

Agreement shall in no way preclude any Participating State from exercising its supervision,

examination, or investigation authority under the laws of the corresponding Participating

State in the instance a determination is made wherein the Company is found not to be

adhering to the requirements of this Agreement or involving any unrelated matter not subject

to the terms of this Agreement, subject to the limitations of Sections I and IV. It is the intent

of the Parties that enforcement authority, other than the process outlined in Section IV, to

address advertising violations that may also violate this Agreement, shall only be exercised

by the Participating States in the event the Company fails to cure the noncompliance as set

forth in Section IV twice in any rolling six-month period during the term of the Agreement.

The enforcement authority of the Participating States for advertising practices outside of the

scope of this Agreement is not restricted.

8) Sharing of Information and Cooperation: The Participating States may collectively or

individually request and receive any information or documents in the possession of the

NDSC. This Agreement shall not limit the Company’s obligations, as a licensee of a

Participating State, to cooperate with any examination or investigation in any Participating

State.

9) Licensure: Subject to the foregoing, nothing in the issuance of this Agreement shall

adversely affect the ability of the Company to apply for or obtain licenses or renewal licenses

in the Participating States provided all applicable legal requirements for any such licenses are

satisfied.

September

CORSCADDEN,

sor, Bureau of Loans

ALABAMA STATE BANKING DEPARTMENT

9-17-2021

By: __ __________ Date: _______________________

SCOTT

Supervi

September 21, 2021

OHIO DEPARTMENT OF COMMERCE

By:

Date: _______________________

9/21/2021

KEVIN R. ALLARD, Superintendent,

Division of Financial Institutions

____ _____________

OKLAHOMA DEPARTMENT OF CONSUMER CREDIT

By: ____________________ Date: _______________________

SCOTT LESHER, Administrator

TENNESSEE DEPARTMENT OF FINANCIAL INSTITUTIONS

By:

GREG GONZALES, Commissioner

Date: _______________________

WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS

By: ________________________________________ Date: _9/20/2021_______________

CHARLES E. CLARK, Director

Exhibit A

MAIL_DATE

MORTGAGE REFINANCE INFORMATION

LOAN TYPE: YEAR-YEAR FIXED REFINANCE

LENDER NAME

STREET

MAIL DATE: MAIL_DATE

CITY, ST ZIP

LOAN AMOUNT:

LOAN_AMNT

INTEREST RATE:

INT_RATE% (APR% APR) FIXED

NEW MONTHLY PAYMENT:

PAYMNT_AMNT

SAMPLE A. SAMPLE –

Payment stated does not include taxes of

insurance premiums. The actual monthly

payment amount will be greater. Rates

Speak to a Home Loan Expert:

are subject to change.

(800) XXX-XXXX

FIRST NAME LAST NAME

STREET

CITY, ST ZIP

Sample,

Lender wants to help review your mortgage.

GENERAL MARKETING CONTENT

You may be eligible to refinance your home loan at a fixed interest rate of INT_RATE%

(APR% APR) for the cost of POINTS point(s) ($COST_OF_POINTS) paid at closing.

See reverse for more details.

Interest rate current as of CURRENT_DATE_MMDDYYYY. Interest rates change daily, so your

exact interest rate will depend on the date you lock your rate.

GENERAL MARKETING CONTENT

Ready to explore your new monthly payment options?

Call (800) XXX-XXXX or visit [Lender URL]

CALL TOLL FREE (800) XXX-XXXX

Or visit [Lender URL]

See reverse for more details.

G216-1210-1

Important Details

In financing your home with a YEAR-Year Fixed-Rate Mortgage, the interest rate is INT_RATE% (APR%

APR) for the cost of POINTS point(s) ($COST_OF_POINTS) paid at closing. On a $LOAN_AMNT, you

would make MONTHLY monthly payments of PAYMNT_AMNT. Payment stated doesn’t include taxes and

insurance, which will result in a higher payment.

The enclosed information is based on one or more of the following sources: home loan

information obtained from internal Lender information and data, county and other public records,

information in your credit report or information purchased from third parties. The information gathered or

purchased by Lender will be used solely for marketing purposes in accordance with federal and state

lending guidelines. Your information will not be shared or sold to other companies.

Additional Assumptions

Offer applies to a first mortgage loan secured by owner-occupied, single-family primary residence. This

offer assumes the borrower’s debt-to-income ratio (DTI) is below 43% and a loan-to-value (LTV) of LTV

%. This offer assumes you have the required full documentation of income and assets, with a credit

score of FICO. To qualify for these loan programs, you must be at least 18 years of age with a valid U.S.

residency. Guidelines may vary for self- employed individuals. Formal approval will be subject to

satisfactory verification of income, assets, credit, property condition and value. Due to changing market

conditions, clients currently in process may not qualify for this offer. By refinancing your existing loan,

the total finance charges may be higher over the life of the loan. Additional restrictions may apply. This is

not a commitment to lend.

To opt out of marketing materials visit [insert Opt-Out URL].

Insert Company Licensing Disclosure

G216-1210-2

Exhibit B

Weekly Mortgage Rates Email

Don’t let the money you’ve invested in your home go to waste. View online

TODAY’S RATES

REFINANCE BUY A HOME CALCUL ATORS ABOUT US

UPDATE: Your Weekly Mortgage Rate

BODY COPY

Get Started Online Chat Online

Current Mortgage Rates

30-Year Fixed

X.XX% X.XX%(APR) POINTS (COST OF POINTS)

15-Year Fixed

X.XX% X.XX%(APR) POINTS (COST OF POINTS)

FHA 30-Year Fixed

X.XX% X.XX%(APR) POINTS (COST OF POINTS)

Important Information

30-Year Fixed-Rate Mortgage: The interest rate is INT_RATE% (APR% APR) for the cost of POINTS

point(s) ($COST_OF_POINTS) paid at closing. On a $LOAN_AMNT loan, you would make monthly

payments of PAYMNT_AMNT. Payment stated doesn’t include taxes and insurance, which will result in

a higher payment. Payment assumes a X.XXX% loan-to-value (LTV).

15-Year Fixed-Rate Mortgage: The interest rate is INT_RATE% (APR% APR) for the cost of POINTS

point(s) ($COST_OF_POINTS) paid at closing. On a $LOAN_AMNT loan, you would make monthly

payments of PAYMNT_AMNT. Payment stated doesn’t include taxes and insurance, which will result in

a higher payment. Payment assumes a X.XXX% loan-to-value (LTV).

FHA 30-Year Fixed Rate Mortgage: The interest rate is INT_RATE% (APR% APR) for the cost of POINTS

point(s) ($COST_OF_POINTS) paid at closing. On a $LOAN_AMNT loan, you would make monthly

payments of PAYMNT_AMNT. Payment stated doesn’t include taxes and insurance, which will result in a

higher payment. Payment includes a one time upfront mortgage insurance premium at X.XX% of

the base loan amount and a monthly mortgage insurance premium (MIP) calculated at X.XX% of the

base loan amount. For mortgages with a loan-to-value (LTV) ratio of X.XX%, the X.XX% monthly MIP will

be paid for the first XX years of the mortgage term. Thereafter, the monthly loan payment will consist

of only principal and interest payments until the end of the loan. Some state and county maximum

loan amount restrictions may apply.

[INSERT CAN-SPAM OPT-OUT]

[INSERT COMPANY LICENSING DISCLOSURE]

The image below reflects the disclosures shown when a consumer clicks the hyperlink

labeled “*Legal Disclosures” located directly below advertised rates on a mortgage lender's

Mortgage Rates web page.

These rates are current as of [Insert Time] PM UTC on [Insert Date].

30-year Fixed-Rate Loan:

An interest rate of INT_RATE% (APR% APR) for the cost of POINTS point(s)

($COST_OF_POINTS) paid at closing. On a $LOAN_AMNT mortgage, you would make

monthly payments of $PAYMNT_AMNT. Monthly payment does not include taxes and

insurance premiums. The actual payment amount will be greater. Payment assumes a loan-to-

value (LTV) of LTV%.

15-year Fixed-Rate Loan:

An interest rate of INT_RATE% (APR% APR) for the cost of POINTS point(s)

($COST_OF_POINTS) paid at closing. On a $LOAN_AMNT mortgage, you would make

monthly payments of $PAYMNT_AMNT. Monthly payment does not include taxes and

insurance premiums. The actual payment amount will be greater. Payment assumes a loan-to-

value (LTV) of LTV%.

FHA 30-year Fixed-Rate Loan:

An interest rate of INT_RATE% (APR% APR) is for the cost of POINTS Point(s)

($COST_OF_POINTS) paid at closing. On a $LOAN_AMNT mortgage, you would make

monthly payments of $PAYMNT_AMNT. Monthly payment does not include taxes and

insurance premiums. The actual payment amount will be greater. Payment includes a one-time

upfront mortgage insurance premium at X.xx% of the base loan amount and a monthly

mortgage insurance premium (MIP) calculated at X.xx% of the base loan amount. For

mortgages with a loan-to-value (LTV) ratio of LTV%, the X.xx% monthly MIP will be paid

for the first XX years of the mortgage term. Thereafter, the monthly loan payment will consist

of equal monthly principal and interest payments until the end of the loan.

Exemplar C