Posted By: swiggles
Reg Z Advertisement Trigger Terms - 01/19/17 03:40 PM
....wasn't sure whether to post this here because it hinges upon Regulation Z advertising requirements....or the Marketing Forum.
Anyway, I am looking at an advertisement for a lot loan. The marketing department wants to disclose the down payment percentage, thus triggering disclosures under 1026.24(d). So we will use an example. The commentary has the below guidance for an "example." What I am stuck on is that it says "examples for typical transactions." Our rates are tiered based on credit score. So do I choose a median rate example. I am betting the marketing department will want to use the lowest rate possible which is probably not attainable for most applicants. We also offer three different lengths of terms...for example 5 years....15 years. Do I have to include an example of each one?
5. Use of examples. A creditor may use illustrative credit transactions to make the necessary disclosures under §1026.24(d)(2). That is, where a range of possible combinations of credit terms is offered, the advertisement may use examples of typical transactions, so long as each example contains all of the applicable terms required by §1026.24(d). The examples must be labeled as such and must reflect representative credit terms made available by the creditor to present and prospective customers.
Anyway, I am looking at an advertisement for a lot loan. The marketing department wants to disclose the down payment percentage, thus triggering disclosures under 1026.24(d). So we will use an example. The commentary has the below guidance for an "example." What I am stuck on is that it says "examples for typical transactions." Our rates are tiered based on credit score. So do I choose a median rate example. I am betting the marketing department will want to use the lowest rate possible which is probably not attainable for most applicants. We also offer three different lengths of terms...for example 5 years....15 years. Do I have to include an example of each one?
5. Use of examples. A creditor may use illustrative credit transactions to make the necessary disclosures under §1026.24(d)(2). That is, where a range of possible combinations of credit terms is offered, the advertisement may use examples of typical transactions, so long as each example contains all of the applicable terms required by §1026.24(d). The examples must be labeled as such and must reflect representative credit terms made available by the creditor to present and prospective customers.