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Reg Z Changes to Trigger Terms

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With the recent changes to Reg Z, have there been any changes/additions to the "trigger terms"?

While there has been an avalanche of regulatory changes and some rules, such as credit cards targeted to college students and some open-end products have changed, the basic trigger terms have not. Reg Z has two marketing sections that address trigger term. These are under Section Section 226.16 and 226.24.

226.24 - Closed end credit
(1) Triggering terms. If any of the following terms is set forth in an advertisement, the advertisement shall meet the requirements of paragraph (d)(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.

Open end advertising is a little more specialized and is required less often by most banks. I'll refer you to .16 as it contains the cross references you'd need if this applies to you. Generally though, these trigger additional disclosures when you discuss the finance charge or other charges. Remember that comments alluding to these in a positive or negative manner may meet the triggering requirements.

First published on 7/05/10

First published on 07/05/2010

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