Has anyone seen guidance on what distinction there is between a discounted rate under Reg Z 226.16(d)(2) and a promotional rate under Reg Z 226.16(d)(6).

As far as I can tell, they seem to be defining the same thing. However, (d)(2)requires disclosure of the term for the "discounted" rate and the rate that would apply afterwards, equally prominent and in close proximity to the "discounted" rate. (d)(6)(C)(ii)calls the rate "promotional" and specifically exempts TV and radio ads from this requirement.

Any insight would be appreciated!
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