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#144725 - 12/31/03 09:46 PM Reg Z ad triggering terms
ForceFull1 Offline
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ForceFull1
Joined: Nov 2003
Posts: 252
smalltown Iowa
Quick question re: triggering terms under Truth In Lending. Our lenders want to include in an ad language such as "own this home for $560 a month!" Would this language, absent any other language in regard to loan term, etc, be a triggering term? Thanks!

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Lending Compliance
#144726 - 12/31/03 09:52 PM Re: Reg Z ad triggering terms
Anonymous
Unregistered

Yes. 12 CFR 226.24 states...

Advertisement of terms that require additional disclosures. (1) If any of the following terms is set forth in an advertisement, the advertisement shall meet the requirements of paragraph (c)(2) of this section:

(i) The amount or percentage of any downpayment.

(ii) The number of payments or period of repayment.

(iii) The amount of any payment.

(iv) The amount of any finance charge.

(2) An advertisement stating any of the terms in paragraph (c)(1) of this section shall state the following terms, as applicable...

The official commentary provides ...

Payment amount. The dollar amount of any payment includes statements such as:

. "Payable in installments of $ 103."

. "$ 25 weekly."

. "$ 1,200 balance payable in 10 equal installments."

In the last example, the amount of each payment is readily determinable, even though not explicitly stated. But statements such as "monthly payments to suit your needs" or "regular monthly payments" are not covered.

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#144727 - 12/31/03 09:53 PM Re: Reg Z ad triggering terms
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,763
On the Net
Quick answer:
ยง226.24 Advertising.
(c) Advertisement of terms that require additional disclosures. (1) If any of the following terms is set forth in an advertisement, the advertisement shall meet the requirements of paragraph (c)(2) of this section:

(iii) The amount of any payment.
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