If we are advertising a grant that is available in our state that provides down payment assistance (and not advertising for a loan product) that requires a 1% contribution by the borrower, would you consider this as a down payment trigger for the Reg Z advertising rules?

I wasn't sure since we really aren't advertising the "loan". We are advertising the availability of the State's "grant".

bump

In the Reg Z advertising rules, downpayment is a triggering term only in transactions where the seller and creditor are the same. So mentioning a down payment assistance grant does not sound like it would be a triggering term.

1026.2(a)(18) Downpayment means an amount, including the value of property used as a trade-in, paid to a seller to reduce the cash price of goods or services purchased in a credit sale transaction. A deferred portion of a downpayment may be treated as part of the downpayment if it is payable not later than the due date of the second otherwise regularly scheduled payment and is not subject to a finance charge.

Good point! I was overlooking that the seller and creditor needed to be the same for that part. I knew it but didn't kick in for some reason. Thanks!