I cannot find the source for the rule about not making the reader scroll several times to get way down to the bottom of the Website page to read the additional disclosures or terms and conditions.
Below are the 3 commentaries dealing with the "direct Link". Notice each says "clearly refer" or "clearly direct" and then "directly" and "where the ... information begins" or "a link that directly takes the consumer to the additional information." It's pretty clear to me that the link must go directly to the disclosures. You can take them to the web page and require them to scroll or page down to find the disclosures.
Here's the Commentary to §1026.24(e) #4:
4. Electronic advertisement. If an electronic advertisement (such as an advertisement appearing on an Internet Web site) contains the table or schedule permitted under §1026.24(e)(1), any statement of terms set forth in §1026.24(d)(1) appearing anywhere else in the advertisement
must clearly direct the consumer to the location where the table or schedule begins. For example, a term triggering additional disclosures may be accompanied by
a link that directly takes the consumer to the additional information.
Here's the Commentary to §1026.16(c)(1) #2:
2. Electronic advertisement. If an electronic advertisement (such as an advertisement appearing on an Internet Web site) contains the table or schedule permitted under §1026.16(c)(1), any statement of terms set forth in §1026.6 appearing anywhere else in the advertisement
must clearly direct the consumer to the location where the table or schedule begins. For example, a term triggering additional disclosures may be accompanied by
a link that directly takes the consumer to the additional information.
Here's the Commentary to §1030.8(a) #9:
9. Electronic advertising. If an electronic advertisement (such as an advertisement appearing on an Internet Web site) displays a triggering term (such as a bonus or annual percentage yield) the advertisement
must clearly refer the consumer to the location where the additional required information begins. For example, an advertisement that includes a bonus or annual percentage yield may be accompanied by a link that
directly takes the consumer to the additional information.