The Federal Trade Commission’s (FTC) recent complaint against Intermundo Media, LLC (Intermundo) alleging deceptive marketing tactics under the FTC Act and Mortgage Acts and Practices – Advertising Rule (MAP Rule) re-emphasizes the ongoing need for mortgage lead generators and mortgage companies that use them to be cautious when advertising the terms and conditions of mortgage products.

The FTC previously issued warning letters to 20 companies, including lead generators, in November 2012. The letters advised companies that their advertisements may be violating the FTC Act or the Mortgage Acts and Practices – Advertising Rule (MAP Rule) by misrepresenting an affiliation with government agencies, offering unqualified low rates or monthly payments, suggesting that no fees or costs were associated with mortgage products or guaranteeing approval for mortgage products. The FTC urged these companies to review their advertisements to ensure compliance with the FTC Act and MAP Rule, but the FTC evidently did not bring enforcement actions against lead generators until earlier this year.