I didn't see your point the first time. Seciton 226.16(d)(1) states
...the advertisement also shall clearly and conspicuously set forth the following... Later, in seciton 226.16(d)(1)(iii), it requires the ad to state
any periodic rate used to compute the finance charge, expressed as an annual percentage rate ...My thoughts are that if you put the interest rate in large print and the APR in small print, I can argue that you did not CLEARLY and CONSPICUOUSLY disclose the APR. I think you have a loop hole, but I wouldn't go for it.
By the way, what's the difference between your interest rate and APR? This is open-end credit. Usually, they are the same.