We are a nonbank mortgage lender who is considering releasing a radio ad. My coworker who is working on the project had the following questions for the BOL community:

1) Would the term “No Closing Costs” be considered a “Trigger or Triggering” term under REG Z Advertising rule for a “Closed End Mortgage” loan and for a radio ad?


2) We would like to have some clarification of Regulation Z for a Radio Advertisement of a “Closed End Mortgage Loan”. Under Regulation Z 1026.24 (g)1, it states that alternative disclosures for Television and Radio would require the use of a multi-purpose telephone number with a recording of the additional disclosure language however, it does not state if a web address can be used to direct the consumer to the disclosure. We would like to know if we can solely use our company web site address for the purpose of the additional disclosure for our radio ad or are we required to use the Multi-purpose telephone number and the web address would be an additional source for the disclosure?

Thanks in advance to all!

1). No. https://www.bankersonline.com/regulations/12-1026-024#d

ii. In the last example, the $1,000 prepaid finance charge can be readily determined from the information given. Statements of the annual percentage rate or statements that there is no particular charge for credit (such as “no closing costs”) are not triggering terms under this paragraph.

2). The radio ad would have to provide the phone number. https://www.bankersonline.com/regulations/12-1026-024#g