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#2239475 - 07/13/20 05:32 PM Used Car Loan Commercial
Bankwoman1 Offline
Diamond Poster
Joined: Dec 2015
Posts: 1,064
Midwest
Am I correct in thinking that mentioning a .25% rate discount on a used car loan, when the payment comes out of an account at our bank automatically, is not a triggering term in any way? I have read the advertising rules for closed end loans in Reg Z and don't see anything regarding this. We are not mentioning any rates, only that they can receive a .25% off if they sign up for automatic payments. This will be a television commercial advertisement.

Anything I am missing?

Thanks!

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#2239481 - 07/13/20 06:31 PM Re: Used Car Loan Commercial Bankwoman1
ComplyCycle Offline
Gold Star
ComplyCycle
Joined: Dec 2014
Posts: 454
That is correct since rate discounts are not a trigger term.

Keep in mind 1005.10(e):

(e) Compulsory use—(1) Credit. No financial institution or other person may condition an extension of credit to a consumer on the consumer’s repayment by preauthorized electronic fund transfers, except for credit extended under an overdraft credit plan or extended to maintain a specified minimum balance in the consumer’s account. This exception does not apply to a covered separate credit feature accessible by a hybrid prepaid-credit card as defined in Regulation Z, 12 CFR 1026.61.

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#2239483 - 07/13/20 06:39 PM Re: Used Car Loan Commercial Bankwoman1
Bankwoman1 Offline
Diamond Poster
Joined: Dec 2015
Posts: 1,064
Midwest
Thanks for the feedback ComplyCycle! I appreciate it.

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