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what is the requirement for keeping advertisements under the map rule?

Under the federal Mortgage Acts and Practices – Advertising Rule (the MAP Rule , also known as Regulation N), the key recordkeeping requirement is that you must keep copies of essentially all materially different advertisements and related supporting documents for a set retention period, typically 24 months.

What the MAP Rule Covers

  • The MAP Rule applies to commercial communications about mortgage credit products, including lenders, brokers, servicers, and even marketing/lead‑gen vendors.
  • A “commercial communication” is defined very broadly and can include print ads, TV/radio spots, emails, texts, websites, social media posts, and other online content about mortgage products.

Core Advertising Obligation

  • The central requirement is that advertisements must not contain any misrepresentation, expressly or by implication, about any term of a mortgage credit product (rates, fees, government affiliation, guarantees, payment amounts, etc.).
  • This applies both to the main message of the ad and to omissions that would make the overall communication deceptive or misleading to a reasonable consumer.

Recordkeeping Requirement for Ads

  • Anyone engaging in commercial communications about mortgage products must retain records of all “materially different” communications covered by the rule.
  • Because “communication” is interpreted broadly, this means you should retain:
    • Copies or screenshots of ads (print, digital, social media, email, text templates, landing pages).
* Any supporting materials used to substantiate claims made in the advertising (e.g., rate sheets, fee disclosures, internal calculations).

What “Materially Different” Means in Practice

  • “Materially different” generally refers to versions of ads that differ in ways a consumer would reasonably care about, such as:
    • Different stated rates, fees, APRs, or payment amounts.
* Different claims about government affiliation, guarantees, or special programs.
  • Minor cosmetic changes that do not alter the substance of the message may not each need to be kept as separate unique advertisements, but firms often keep them anyway as a conservative compliance practice.

Practical Steps to Stay Compliant

  • Implement an internal process to:
    1. Approve mortgage ads before release, checking for any potentially deceptive claims or omissions.
2. Archive final versions of each materially different ad across all channels, plus the date and distribution context (where and how it ran).
3. Store substantiation documents (rate sheets, calculations, program terms) alongside the ad files for at least the required retention period.

Information gathered from public forums or data available on the internet and portrayed here.