Intro to Mortgage Origination Examinations Training - July 2025

Internal Use Only

How does the FTC Typically Determine if an ad is deceptive?  Looks at the ad from a reasonable consumer’s view  Looks at both express and implied claims  Looks at what the ad does not say

 Looks at whether the claim would be “material”  Looks at whether the advertiser has sufficient evidence to support the claims in the ad

Internal Use Only

Group Question Has anyone received an advertisement you felt may have violated any of these laws? If so, what was it in the advertisement that made you feel that way?