To all fellow harassed compliance professionals...Reg. Z changes effective October 2009: The Federal Register discussion page (44576) of the final rule regarding advertising with respect to balloon payment says the regulators were revising this section to clarify that only statements of the amount of any minimum periodic payment triggered the required disclosures. However neither the text of the final rule nor the commentary seems to make this clarification. They show the same language as the existing version of the rule. Am I missing something? Also, did they add an additional disclosure requirement (i.e. the amount and timing of the balloon payment)? I don’t remember that requirement. Love that job security!

New Reg. Z Text (emphasis added by me)
226.16(d)(3) Balloon payment. If an advertisement contains a statement of any minimum periodic payment and a balloon payment may result if only the minimum periodic payments are made, even if such a payment is uncertain or unlikely, the advertisement also shall state with equal prominence and in close proximity to the minimum periodic payment statement that a balloon payment may result, if applicable.36e A balloon payment results if paying the minimum periodic payments does not fully amortize the outstanding balance by a specified date or time, and the consumer is required to repay the entire outstanding balance at such time. If a balloon payment will occur when the consumer makes only the minimum payments required under the plan, an advertisement for such a program which contains any statement of any minimum periodic payment shall also state with equal prominence and in close proximity to the minimum periodic payment statement: (i) That a balloon payment will result; and (ii) The amount and timing of the balloon payment that will result if the consumer makes only the minimum payments for the maximum period of time that the consumer is permitted to make such payments.
New Reg. Z Comment
9. Balloon payment. See comment 5b(d)(5)(ii)–3 for information not required to be stated in advertisements, and on situations in which the balloon payment requirement does not apply.