What is considered advertising under rule z?

Regulation Z broadly defines advertisements as commercial messages provided on any medium that promotes, directly or indirectly, a credit transaction. ii) Include a clear and visible statement that the person making the announcement is not associated with or acting on behalf of the consumer's current lender. If the information required in Articles 1026.24 (f) (i) and 1026.24 (f) (i) (A) and (B) is the same size as the announced fees or payments that trigger the required disclosures, the disclosures are considered equally prominent. Unlike the transactional disclosure of an annual percentage rate under § 1026.18 (e), the announced annual percentage rate need not include a descriptive explanation of the term and can be expressed by the abbreviation APR.

In variable rate plan announcements, if the announced annual percentage rate is based on (or the advertised payment is derived from) the index and margin that will be used to make rate (or payment) adjustments over the term of the loan, then there is no promotional rate or promotional payment. The seller is usually aware of these additional charges when they place the listing and should not ignore what they know is common practice when advertising the property. Section 1026.16 (c) (allows creditors to collect credit information in one place in a catalog or other multi-page advertisement or electronic advertisement (such as an advertisement that appears on an Internet website). If an ad indicates a financial charge rate, it will indicate the fee as an “annual percentage rate”, using that term.

For example, a creditor may announce conditions that will be offered only for a limited period or conditions that will be available at a future date. (ii) In the case of an advertisement only for non-variable rate transactions where payment will increase (for example, Section 1026.16 (a) is not intended to inhibit the promotion of new credit programs, but to prohibit advertising of terms that are not and will not be available. The announcement may also show the effect of the discount on the payment schedule for the discount period, but this will trigger additional disclosures under § 1026.24 (d). When a third party (such as a seller) or creditor wishes to promote the availability of reduced interest rates (consumer or seller purchases), the announced annual percentage rate must be determined in accordance with the commentary in § 1026.17 (c) regarding the basis of transactional disclosures for purchases.

According to comment 16 (c) -1, a catalog or multi-page advertisement is considered a document for the purposes of § 1026.16 (g) (. You should review open credit ads to ensure that discounted rates clearly indicate the time period in which they are in effect, as this is sometimes confusing to the consumer. See Interpretation of 24 (f) Rate and Payment Disclosure in Home Secured Credit Ads in Supplement I. The commentary to Regulation DD provides some options for this scenario by allowing a message explaining that rates may vary by term or account type, with examples provided that.

Patti Goldenman
Patti Goldenman

General bacon lover. Hipster-friendly travel guru. Proud bacon ninja. Incurable zombie trailblazer. Professional bacon fanatic.

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