We are trying to avoid all triggers for a mortgage flyer.

We have "10% down - No PMI". So that is fine, but we need to show that jumbo loans are ineligible. If we put "maximum loan amount is $484,350", does this trigger more disclosures?

I don't believe so.

It's housing credit, so the EHL "doghouse"...but that can be plastered anywhere you want.

I'm confused, though. Regulation Z Advertising for closed end credit lists the following triggering terms:

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.

If you're showing 10% downpayment, isn't that one of the triggering terms? Am I missing something?

Skittles, does it have to do with the that not being a requirement to get the loan, but rather a requirement to avoid PMI?

Downpayment only occurs when it is a credit sale.

1026.2(a)(18) Downpayment means an amount, including the value of property used as a trade-in, paid to a seller to reduce the cash price of goods or services purchased in a credit sale transaction. A deferred portion of a downpayment may be treated as part of the downpayment if it is payable not later than the due date of the second otherwise regularly scheduled payment and is not subject to a finance charge.

Thank you for the reminder Randy. I forgot that part.

That's commonly missed by many auditors/examiners. I have helped many clients that have been incorrectly cited for this.

Definitions, definitions, definitions! Sometimes they are more important than the rule itself.