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#2194500 - 10/02/18 08:19 PM I don't think these are triggering terms
Bec Offline
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Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
Mortgage flyer that has the following: Our Mortgage "$1199 or less in closing costs"
There doesn't appear to be any triggering terms in this, are there?
If there are no triggering, that means we don't need any disclosure type language including the payment example, etc.
Right?
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#2194511 - 10/02/18 09:26 PM Re: I don't think these are triggering terms Bec
Norman Paperman Offline
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Norman Paperman
Joined: Aug 2012
Posts: 1,700
48.934476, -114.343735
What are you defining as "closing costs"? How in the world can you guarantee that Total Closing Costs (LE line J) would be less than $1,199? Consider escrow, prepaid insurance, taxes, etc.
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#2194531 - 10/03/18 12:31 PM Re: I don't think these are triggering terms Bec
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
How much of the closing costs are finance charges (d)(1)(iv)?

(d) Advertisement of terms that require additional disclosures. (1) Triggering terms. If any of the following terms is set forth in an advertisement, the advertisement shall meet the requirements of paragraph (d)(2) of this section:

(i) The amount or percentage of any downpayment.

(ii) The number of payments or period of repayment.

(iii) The amount of any payment.

(iv) The amount of any finance charge.
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