Advertising: Closed-End Credit Triggering Terms

If you advertise closed-end credit, there are several “triggering” terms you need to be aware of.  Specifically, if you mention any of the following in an advertisement:

  1. The amount or percentage of down payment;
  2. The number of payments or period of repayment;
  3. The amount of any payment; and,
  4. The amount of any finance charge.

You are required to provide the following additional information within the advertisement:

  1. The amount or percentage of the down payment;
  2. The terms of repayment, which reflect the repayment obligations over the full term of the loan, including any balloon payment;
  3. The “annual percentage rate”, or “APR”, using one of these terms; and,
  4. If the rate may be increased after consummation of the loan, that fact.

While this may seem pretty straightforward, there are some additional things to consider.

David explains more in the video.


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Published
2024/12/16
Jerod Moyer

Jerod Moyer

Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru. Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports-related!

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