I've talked myself into circles and would appreciate additional perspective.

Based on the research that I've done, I'm confident that if we ran an ad that read "No closing costs" that would not be considered a triggering term.

But, what if we ran "We'll cut the origination charges in half"? I can convince myself that this is a triggering term, then I can provide the disclosures required to include the amount of downpayment (required minimum equity); repayment obligations over the life of the loan, and APR - but that's where I start to go in circles.

If we're going to offer this broadly, it can apply to a lot of different loan products, just for example a 1, 3, or 5 year ARM. I can choose an amortization period for the loan easily enough, but when I'm building a disclosure, am I going to have to build a disclosure for whichever ARM that I choose to calculate? IE - 60 payments of ____; 60 payments of ____, and then 180 payments of ____ (like the TIL)?

The commentary isn't really helpful, so any nudge in the right direction will be greatly appreciated.

I wouldn't call that a trigger term. There's no way to come up with the dollar amount of a component of the FC unless you state the full amount of the "origination charges" elsewhere in the ad.