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We are going to run some ads in our local newspaper and have a question about trigger terms from Regulation Z. I see from 1026.24 oficial interpretation that if you state specific payment periods you must disclose additional terms. My question is, if we ran an ad that stated “Now Offering Long Term Fixed Rate Loans” would this be considered a trigger term. In the official interpretation it gives the examples of what are not considered payment periods, “pay weekly”, “monthly payment terms arranged”, or “take years to repay”. It states that these statements “do not indicate a time period over which a loan may be financed”. I am thinking that as long as we do not specifically state a term, it would not be considered a trigger term. Thoughts? Thanks!
I would agree “long term” does not meet the definition of a payment period trigger term. The commentary clarifies that a specific period of time or payment term.
Reg Z Comment 1026.24(d)(1)-2 says:
The number of payments required or the total period of repayment includes such statements as:A. 48-month payment terms.
B. 30-year mortgage.
C. Repayment in as many as 36 monthly installments.
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