Ameritrust Mortgage Corporation

Advertising and Marketing Policy

Effective Date: 25th September, 2024

Purpose

This policy outlines the guidelines and standards that all employees, agents, and representatives of Ameritrust Mortgage Corporation ("Ameritrust") must follow when creating, publishing, or distributing any advertising or marketing materials, whether online or offline. The purpose of this policy is to ensure compliance with all applicable federal and state laws and regulations, including but not limited to the Truth in Lending Act (TILA), the Real Estate Settlement Procedures Act (RESPA), the Equal Credit Opportunity Act (ECOA), the Fair Housing Act, and any relevant state-specific advertising regulations.

General Principles

• Accuracy and Truthfulness:

  All advertising and marketing materials must be accurate, truthful, and not misleading. They must not misrepresent any aspect of Ameritrust's products, services, terms, or conditions.

• Clarity and Transparency:

  All information presented in advertising and marketing materials must be clear, concise, and easily understandable by the average consumer. Avoid using jargon or technical terms that may be confusing.

• Compliance with Laws and Regulations:

  All advertising and marketing materials must comply with all applicable federal and state laws and regulations. This includes, but is not limited to, the following:

  • TILA:

    Clearly disclose all material terms of credit, including APR, finance charges, and total payments.

  • RESPA:

    Do not engage in any prohibited practices, such as kickbacks or referral fees.

  • ECOA:

    Do not discriminate against any applicant based on protected characteristics.

  • Fair Housing Act:

    Do not engage in any discriminatory advertising or marketing practices.

  • State Laws:

    Comply with all state-specific advertising and marketing regulations, including any licensing requirements or restrictions on certain types of advertising.

Specific Guidelines

• Trigger Terms:

  When using trigger terms such as "low rates," "no closing costs," or "fast approval," ensure that any qualifying conditions or limitations are clearly disclosed.

• Testimonials and Endorsements:

  Any testimonials or endorsements used in advertising or marketing materials must be genuine and reflect the actual experiences of the individuals involved. Do not use misleading or deceptive testimonials or endorsements.

• Social Media and Online Advertising:

  All social media posts, online advertisements, and other digital marketing materials must comply with the same standards as traditional advertising and marketing materials.

• Third-Party Marketing:

  Any third-party vendors or partners involved in the creation or distribution of advertising or marketing materials on behalf of Ameritrust must also adhere to this policy.

Review and Approval Process

• Pre-Approval:

  All advertising and marketing materials must be reviewed and approved by the Compliance Department before they are published or distributed.

• Recordkeeping:

  Maintain records of all advertising and marketing materials, including the date of publication or distribution, the target audience, and any approvals obtained.

Consequences of Non-Compliance

• Disciplinary Action:

  Any employee, agent, or representative who violates this policy may be subject to disciplinary action, up to and including termination of employment or contract.

• Legal and Regulatory Penalties:

  Non-compliance with advertising and marketing regulations can result in significant legal and regulatory penalties, including fines and enforcement actions.

Policy Updates

This policy will be reviewed and updated periodically to ensure ongoing compliance with all applicable laws and regulations. All employees, agents, and representatives are responsible for staying informed about any changes to this policy.

Disclaimer

Ameritrust Mortgage Corporation, NMLS #217229 located at 17341 Irvine Blvd., Suite 285, Tustin, CA 92780. Ameritrust Mortgage Corporation does not provide legal, tax, or financial advice or guidance and is not associated with any government agency. This is not an offer for extension of credit nor a commitment to lend. Programs, rates, terms and conditions subject to change without notice. Certain restrictions may apply. All approvals are subject to underwriting guidelines and minimum credit requirements. Not all loans or products are available in all states. As a result of refinancing, your total finance charges may be higher over the life of the loan. Minimum and maximum loan amounts apply. For current licensure information, please visit: www.nmlsconsumeraccess.org.

By adhering to this policy, Ameritrust Mortgage Corporation can demonstrate its commitment to fair and transparent advertising and marketing practices, build trust with its customers, and maintain compliance with all applicable laws and regulations.

Ameritrust Mortgage Corporation