Can we state there is a 20 percent down payment that may be required or would this be a trigger term. In the commentary it looks like a trigger term but then refers to a definintion of down payment which only refers to the "creditor as the seller"., therefore not making this a trigger term for a close end traditional mortgage loan. Correct?

I do not believe that it is a trigger term for the reason that you cite - down payment only refers to the "creditor as the seller".