Ohio mortgage advertising rules

License and NMLS ID display

Statute. Guidance is not law.

Last verified 2026-09-17.

STATUTE. R.C. § 1322.46(A): a registrant or MLO shall disclose, in any printed, televised, broadcast, electronically transmitted or published advertisement "including on any electronic site accessible through the internet," "the business name of the registrant or mortgage loan originator and the unique identifier of the registrant or mortgage loan originator."

REGULATION. O.A.C. 1301:8-7-07(A) goes further. Every advertisement must, "in manner or form that is reasonably understandable to the average borrower":

• (A)(1) State the registrant's name as printed on its certificate of registration (trade/fictitious name permitted if approved);
• (A)(2) "State the registrant's certificate of registration number and NMLS unique identifier";
• (A)(3) "State the full name or other names of the licensee as listed on the NMLS consumer access website, the licensee's license number, and NMLS unique identifier whenever a licensee's name is placed in an advertisement"; and
• (A)(4) "State the registrant's office address as listed on the registrant's certificate of registration."

Conjunctive or disjunctive. this is the key Ohio nuance. The four elements of (A)(1)–(A)(4) are joined by "and" and are CONJUNCTIVE. But the rule then supplies two express disjunctive escape hatches:

• (B). "a registrant may opt to state only its NMLS unique identifier in lieu of stating both its certificate of registration number and NMLS unique identifier."
• (C). "a licensee may opt to state only the licensee's NMLS unique identifier in lieu of stating both the licensee's license number and NMLS unique identifier."

So the practical minimum for a company ad is: registrant name + NMLS unique identifier (using the (B) option) + registrant office address. All three together. The (A)(3) licensee block is conditionally triggered. it applies "whenever a licensee's name is placed in an advertisement," so naming an individual loan officer in a social post pulls in that individual's NMLS-listed name and unique identifier.

Note the office-address requirement. Ohio is one of only two states in this batch (with New York) requiring a physical address in advertising, and Ohio has no large-office carve-out equivalent to NY's >10-offices exception.

Prohibited claims

Regulation. Guidance is not law.

Last verified 2026-09-17.

It is a violation to place an advertisement containing "any material misrepresentation regarding any term of a residential mortgage loan, including":

• (E)(3). SUPERLATIVES, EXPRESSLY. Prohibited: "Using unqualified superlatives including 'lowest rates,' 'lowest costs,' 'lowest payment plan,' or 'cheapest loans,' or that makes offers that cannot be reasonably fulfilled or substantiated." *Attaches to: rates, costs, payment plans and loan pricing. and, via the "offers that cannot be reasonably fulfilled or substantiated" clause, to unsubstantiable offers generally. The word "unqualified" is load-bearing: a properly qualified/substantiated superlative is not per se banned.*
• (E)(1). SPEED/GUARANTEE. Prohibited: "Guaranteeing or implying that residential mortgage loans will be approved or closed in an unreasonably short period of time given market conditions at the time of the advertisement." *Attaches to: approval/closing timing claims.*
• (E)(2). SPECIAL TERMS / GUARANTEED RATES. Prohibited: "Indicating that special terms, reduced rates, guaranteed rates, particular rates or any other special feature of residential mortgage loans are available unless the advertisement clearly states any limitations that apply." *Attaches to: terms, rates, and any special feature. Note "guaranteed rates" is expressly named.*
• (E)(4). "NEW"/"REDUCED" STALENESS. Prohibited: "Using the words 'new' or 'reduced' or similar words in connection with costs for more than ninety days after the costs become effective." *Attaches to: costs only. This is a hard 90-day clock.*
• (E)(5). CREDIT-IMPAIRED TARGETING. Prohibited: indicating loans are available to borrowers with "previous bankruptcy," "no credit," "bad credit," or the like "unless the advertisement clearly explains any limitations that apply, or states that 'certain limitations apply, call for details.'" In any written advertisement, that text "shall be clearly legible."
• (E)(6). GOVERNMENT LOOK-ALIKE, EXPRESSLY. Prohibited: "Using an official government design, format, symbol, logo, or seal unless its use is required or allowed by the governmental entity." *Attaches to: visual government indicia.*
• (E)(7). THIRD-PARTY NAME CONFUSION. Prohibited: "Using the name of a person or entity that confuses or misleads a borrower as to the true identity of the registrant placing or sending the advertisement regardless of any statement elsewhere in the advertisement identifying the true identity of the registrant or licensee." *The emphasized clause defeats the common "we disclose our real name in the fine print" defense.*

STATUTE. R.C. § 1322.40(B) independently prohibits "false or misleading statements of a material fact, omissions of statements required by state or federal law, or false promises regarding a material fact, through advertising or other means," and § 1322.40(I) incorporates Ohio's UDAP statute (R.C. 1345.01–1345.13).

Federal MAP Rule incorporated as state law. O.A.C. 1301:8-7-07(F): "A violation of 12 C.F.R. 1014.2, 1014.3, or 1014.4, as in effect on May 1, 2024, shall constitute a violation of this rule." This gives Ohio's Superintendent direct state enforcement of Reg N.

Rate advertising

Statute. Guidance is not law.

Last verified 2026-09-17.

• STATUTE. R.C. § 1322.46(B): "In making any advertisement, a registrant shall comply with 12 C.F.R. 226.16, as amended." Compliance trap: 12 C.F.R. 226.16 is the Federal Reserve's Reg Z advertising rule. Rulemaking authority for Reg Z transferred to the CFPB, and the operative open-end/closed-end advertising provisions for most creditors are now 12 C.F.R. 1026.16 and 1026.24. The Ohio statute was not updated. The cited section also covers open-end credit advertising specifically. Read it as a general "comply with Reg Z advertising" mandate elevated to state law, but the literal citation is stale.
• REGULATION. 1301:8-7-07(E)(2) requires that any advertised reduced/guaranteed/particular rate "clearly state[] any limitations that apply."
• REGULATION. 1301:8-7-07(E)(4) bars "reduced" language as to costs beyond 90 days.
• No Ohio-specific rate-lock-terms or standalone "rates subject to change" mandate was located (contrast NY § 38.2(e)(5)). Ohio reaches the same ground through (E)(2)'s "clearly states any limitations."

Ad filing, prior approval, retention

Regulation. Guidance is not law.

Last verified 2026-09-17.

• No prior approval or filing requirement found.
• Website currency. REGULATION, 1301:8-7-07(D): "It is a violation for a registrant to fail to update its website within thirty calendar days after any information becomes outdated or expired." This is an affirmative 30-day website maintenance deadline and is unusual; it converts stale rate tables, expired promotions and departed-loan-officer pages into standalone violations.
• Advertising retention. O.A.C. 1301:8-7-06 [REGULATION] [OFFICIAL, codes.ohio.gov], effective 19 September 2025, retrieved 2026-09-17:

> "(A) In accordance with division (B) of section 1322.34 of the Revised Code and division (C)(3) of section 1322.05 of the Revised Code, the four-year retention period commences on the date the residential mortgage loan is closed or, if the residential mortgage loan is not closed, the date of the withdrawal or denial of the residential mortgage loan application. … The retention period for advertisements commences from the date the advertisements are published, broadcast, or disseminated." > "(G)(3) A file of all advertisements." Advertisements are a required record. The clock for advertisements starts on publication, broadcast, or dissemination, in accordance with the four-year period in R.C. 1322.34.

Social media and character-limited media

Statute. Guidance is not law.

Last verified 2026-09-17.

REGULATION. O.A.C. 1301:8-7-01(A), definition of "Advertisement"/"advertising," expressly includes:

"The term advertisement and advertising includes web pages and social media posts, but does not include de minimis promotional items such as pens, pencils, balloons, and coffee mugs."

The full definition is extremely broad. "any written or oral statement, illustration, or depiction, whether in English or any other language, that is designed to effect a sale or create interest in purchasing goods or services". and enumerates telemarketing scripts, on-hold scripts, upsell scripts, training materials provided to telemarketing firms, infomercials, "the internet, cellular network, or any other medium."

No abbreviated-disclosure accommodation for character-limited media exists. A social media post is an advertisement and carries the full 1301:8-7-07(A) name + identifier + address load. Note "cellular network" is named, which reaches SMS.

Narrowing provision. 1301:8-7-07(H): "Written or oral statements that are purely informational and not designed to effect or create interest in purchasing the services of a registrant or licensee are not subject to this rule." This is the only relief valve, and it turns on purpose, not on format or length.

Penalties

Statute. Guidance is not law.

Last verified 2026-09-17.

R.C. § 1322.50(A)(2) [STATUTE] [OFFICIAL. codes.ohio.gov], retrieved 2026-09-16:

"Impose a fine of not more than one thousand dollars, for each day a violation of a law or rule is committed, repeated, or continued. If the registrant, letter of exemption holder, or licensee engages in a pattern of repeated violations of a law or rule, the superintendent may impose a fine of not more than two thousand dollars for each day the violation is committed, repeated, or continued."

R.C. § 1322.50(B)(2) authorizes civil penalties "for unregistered or unlicensed conduct of not more than five thousand dollars per violation." The Department's 2022 notice states that advertising violations may be subject to administrative enforcement action. That notice is [GUIDANCE].