"Tired to find it ..." Yes, it can be tiring trying to find something in Reg Z.
The disclosure of the "downpayment" in credit sales transactions is required by section 1026.18(j). But if you check out comment 18-3.i., which give the scope of the coverage of section 18, this is what you will find:
Scope of coverage. i. Section 1026.18 applies to closed-end consumer credit transactions, other than transactions that are subject to § 1026.19(e) and (f). Section 1026.19(e) and (f) applies to closed-end consumer credit transactions that are secured by real property, other than reverse mortgages subject to § 1026.33. Accordingly, the disclosures required by § 1026.18 apply only to closed-end consumer credit transactions that are:
A. Unsecured;
B. Secured by personal property that is not a dwelling;
C. Secured by personal property that is a dwelling and is not also secured by real property; or
D. Reverse mortgages subject to § 1026.33.
In other words, the disclosure isn't required for loans covered by the TRID rules.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8