Answer:
How much disclosure is necessary depends on what else is said in the ad. Simply stating the APR on a closed-end loan ad is not of itself a trigger term, but if you state "60 month car loan," that is a trigger term and would require more disclosure under Reg Z. You should really familiarize yourself with the requirements under Reg Z section 226.24 and the accompanying Official Staff Commentary.
Reg Z is not the only consideration though. You may also have UDAP issues that need to be addressed through additional disclaimers. Things like "subject to credit approval" and "credit score may affect rate" are disclaimers that have generally come about because of bank lawyers and compliance officers wanting to make sure there is no misleading or confusion.
First published on BankersOnline.com 9/27/10
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