Introduction to Mortgage Origination Examinations Training eBook

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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

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When is an advertisement likely to mislead?