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Need Help Understanding Reg Z Trigger Terms

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Question: 
I’m having some trouble understanding when a “term” is considered a trigger term for Reg Z advertising. I’ve read the Reg and I am more confused than ever. Can you recommend a good training source and some other resources to get me up to speed?
Answer: 

Before looking for help elsewhere, be sure you've used Reg Z effectively. Read the regulation first- don't start with the Commentary. Notice that Reg Z contains two sets of advertising rules (226.16 for open-end credit and 226.24 for closed-end credit) because the standards are different for these two types of consumer credit. DO NOT try to apply one set of rules to the other type of credit. After you're comfortable with the broad principles, then read the Commentary. You should also study the Federal Trade Commission's excellent Consumer Credit Advertising Guide for lenders here.

DO NOT look at the advertisements of other lenders (especially web-based ads) and assume that they comply with Reg Z. There's an excellent chance that they do not comply. Regulators have paid very little attention to Reg Z advertising compliance and lenders tend to narrow the focus of their compliance programs to matters of concern to their regulators.

First published on BankersOnline.com 7/24/06

First published on 07/24/2006

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