Internal bank flyer reads "...available up to 4 years...". Based upon 1026.24(d)'s mention of repayment period as a triggering term, and the commentary's explanation, I believe the phrase triggers additional disclosures. What say you?

Thanks!

Yes

2. Payment period. i. The number of payments required or the total period of repayment includes such statements as:

A. 48-month payment terms.

B. 30-year mortgage.

C. Repayment in as many as 36 monthly installments.