This question was brought up a few years back, but I need to add on to it and make it specific.

For an outside digital sign "Auto Rates as low as 5.99%"

Do we need to state APR? Can it be the interest rate?

No other triggering terms used.

Closed-end loans? There are no "outdoor" exceptions in 1026.24

1026.24(c) Advertisement of rate of finance charge. If an advertisement states a rate of finance charge, it shall state the rate as an “annual percentage rate,” using that term. If the annual percentage rate may be increased after consummation, the advertisement shall state that fact. If an advertisement is for credit not secured by a dwelling, the advertisement shall not state any other rate, except that a simple annual rate or periodic rate that is applied to an unpaid balance may be stated in conjunction with, but not more conspicuously than, the annual percentage rate. If an advertisement is for credit secured by a dwelling, the advertisement shall not state any other rate, except that a simple annual rate that is applied to an unpaid balance may be stated in conjunction with, but not more conspicuously than, the annual percentage rate.

We are restructuring the auto loan rate tables (closed end non-RE) on our website. Today we display a "range" of APRs for each term. I want to make the process easier when rates change, so if we state, "As low as" and only display the lowest APR in the table, can we just provide one sample payment scenario for the lowest APR?

I've seen varying opinions on advertising "as low as" APRs. Do you recommend going this route for closed end, non-RE consumer loans?

Only issue would be if you care to fully explain in detail what they need to do it get the "as low as" APR.

So, providing a range is the "safer" way to disclose the APR? How many sample payment scenarios should be provided? I've seen a sample for the lowest APR and the highest APR but would rather provide just one.

Do we even have to provide a sample payment scenario? Below is a section from the commentary (1026.24(d)(2)5) that starts with "A creditor may use..." These are closed-end auto/RV loans not secured by a dwelling. Am I interpreting this correctly?

5. Use of examples. A creditor may use illustrative credit transactions to make the necessary disclosures under §1026.24(d)(2). That is, where a range of possible combinations of credit terms is offered, the advertisement may use examples of typical transactions, so long as each example contains all of the applicable terms required by §1026.24(d). The examples must be labeled as such and must reflect representative credit terms made available by the creditor to present and prospective customers.

If you pull a trigger in (d)(1) you have to include all the information in (d)(2).

If this is (as you say) nothing but closed-end, non-real-estate rates, then from what you've told us, you aren't mentioning any of the (d)(1) trigger terms in your rateboard page. APR, alone, is not a trigger term for closed-end. Traditionally, the most common trigger terms in rateboards was the maturities (in months) that paired with the different rates listed. If your rateboard doesn't mention repayment periods, then it doesn't look like you need any repayment examples.

Thanks for your comment, Richard.

Our rate board does list every term (36 months, 48 months, etc.) with an APR range for each. Is it acceptable to provide just one payment example in the disclosure? For example, a $20,000 loan for 36 months at XX% is $XXX. Providing examples for each term is a little scary from a maintenance standpoint.

A single example for each term should be enough. With bait & switch and other fairness concerns in mind, I'd avoid using the lowest APR in each range and go for one somewhere in the middle.