You can mention the term "down payment" or "20% down" in an ad without it being considered a "down payment" as defined in the regulation, as long as you are not a seller in the transaction. For a bank, credit sales most often arise when selling foreclosed real estate or other repossessed collateral (automobiles, for example).
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8