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This opinion was issued in the second quarter of 1999.
A bank proposes to offer consumer loans through the internet. Consumers whose applications were approved would be offered special terms such as a reduced interest rate off the initial interest rate for similar loans granted to non-internet borrowers or a cash rebate. Mass. Gen. Laws 140D and its implementing regulation 209 CMR 32.00 et seq. govern Truth-in-Lending disclosures. The proposed program would not be in conflict with said chapter 140D and 209 CMR 32.00 et seq. In addition, both options of special terms for internet loans would have to be properly disclosed pursuant to 209 CMR 32.00 et seq. Such disclosure would have no effect on the disclosure to be given consumers who borrowed from the bank but not on the internet.