SAFE MLO Ethical Conduct, Fair Lending & Advertising question: rate from a loan

SAFE MLOEthical Conduct, Fair Lending & Advertising

An MLO wants to post client testimonials on his website, including one that says 'He got me a 3% rate' from a loan that closed five years ago. What is the concern?

A None, because testimonials are not advertising
B None, as long as the client consented
C It is illegal to post any testimonial
D It may mislead readers about rates available today

Show the answer and explanation

Answer: D. It may mislead readers about rates available today

Testimonials in advertising are representations by the advertiser; one implying current availability of an old rate can be misleading about the terms available, contrary to the MAP Rule (12 CFR 1014.3) and the Model State Law's ban on advertising terms not actually available. Context or removal fixes it. Source: 12 CFR 1014.3; CSBS/AARMR Model State Law, prohibited acts (as at 11 Oct 2026).

Common mistake

Assuming client consent makes any testimonial accurate.

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Study note: Ethical Conduct, Fair Lending & Advertising SAFE MLOpractice questions & mock exams

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Original study material mapped to the public NMLS Content Outline; not a real test question.Not affiliated with or endorsed by NMLS, CSBS or SRR. Verify figures and rules against current guidance before relying on them.