I'm trying to determine if we can place all the fine print disclosures on a HELOC ad at the bottom of a letter where the letter is created in such a manner that the bottom portion is an application and can be torn off. Seems to me the fine print would need to be with the actual letter part of the form and not at the bottom that can be torn off and separated from the letter where the trigger terms are located. However, when I review Reg Z commentary, it says the font size and location do not matter. Am I reading the commentary wrong?

LtR - when I am sending out letter like that with a bangtail attached coupon, I always put disclosures on both pieces. Not sure if I actually have to, but I think it's the right thing to do.