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#492037 - 02/01/06 10:23 PM Reg Z - Closed End Loan Ad
Last Mango Offline
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Joined: Mar 2001
Posts: 293
Too Far From the Beach
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?
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#492038 - 02/02/06 03:46 PM Re: Reg Z - Closed End Loan Ad
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
Because a dollar amt is used, additional disclosures are triggered. Reg Z is not very clear on this.
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#492039 - 02/02/06 05:38 PM Re: Reg Z - Closed End Loan Ad
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 10,171
Toano, VA
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."
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#492040 - 02/02/06 07:45 PM Re: Reg Z - Closed End Loan Ad
Last Mango Offline
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Joined: Mar 2001
Posts: 293
Too Far From the Beach
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.
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#492041 - 02/02/06 08:50 PM Re: Reg Z - Closed End Loan Ad
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 10,171
Toano, VA
Quote:

...each possible number from "0" up to the dollar amount mentioned is considered a payment that is readily determinable.



I think you'll have an uphill battle with your regulator if you don't add a f'rinstance somewhere in the ad.
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