Good Afternoon,

I know that the amount of any finance charge is a triggering term under TILA (Reg Z), but any thoughts on whether "no origination fee" is a triggering term?

Thank you for your input.

Open end credit:
1. Triggering terms. Negative as well as affirmative references trigger the requirement for additional information. For example, if a creditor states no interest or no annual membership fee in an advertisement, additional information must be provided.

Thank you for the feedback. It is very helpful.

What if the loan is closed-end, an unsecured personal loan, to be specific?

The closed end rules are found here: https://www.bankersonline.com/regulations/12-1026-024

Negative references in closed-end credit advertising is not a trigger term like it is in open-end credit.

The open-end rules can be found here: https://www.bankersonline.com/regulations/12-1026-016

Thanks a bunch, Carey!