I'm hoping I can get someone to confirm my thoughts on a closed end loan ad. The ad refers to helping the public lower their existing loan payments to less than $100 on a $4k balance. The payment amount is a triggering term under 226.24(c)(1)(III). However, because the ad says "less than", it technically does not mention the payment amount and therefore this would not trigger the other disclosures in (c)(2), right?

Because a dollar amt is used, additional disclosures are triggered. Reg Z is not very clear on this.

Disclosures are triggered. See Comment 1 on Sec. 226.24(c) which says, in part, "These provisions apply even if the triggering term is not stated explicitly, but may be readily determined from the advertisement."

I read the footnote but was thinking that the triggering term could not be readily determined because "less than" covers an entire range of possible numbers beginning with "0". However, I guess your take is that each possible number from "0" up to the dollar amount mentioned is considered a payment that is readily determinable.