Compliance

Trigger terms (Regulation Z)

Definition

Trigger terms are specific credit terms that, when used in a closed-end credit advertisement, require additional disclosures under Regulation Z (12 CFR 1026.24). Stating a down payment amount, the number of payments, a payment amount or a finance charge triggers disclosure of the down payment, repayment terms and APR.

Trigger terms (Regulation Z), explained

Mortgage marketers should have compliance review any page that states rates or payments — including calculator landing pages.

Source: CFPB — Regulation Z advertising rules (12 CFR 1026.24)

FAQ

Trigger terms (Regulation Z): quick questions

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Q.01What is trigger terms (regulation z)?
Trigger terms are specific credit terms that, when used in a closed-end credit advertisement, require additional disclosures under Regulation Z (12 CFR 1026.24). Stating a down payment amount, the number of payments, a payment amount or a finance charge triggers disclosure of the down payment, repayment terms and APR.
Q.02Does a calculator result count as advertising a trigger term?
Calculator output is generated from the visitor’s own inputs, but the page copy around it is advertising. Have compliance review headlines and examples that state payments or terms.

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