Is "No Down Payment" A TILA Triggering Term?

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Question:

Is No Down Payment in advertising a consumer mortgage on my bank's website a TILA triggering term?

Answer:

No...for two reasons (both explained in the Official Commentary to Section 1026.24(d)(1), comment #1.)

Reason #1 - except for bank-financed sales of OREO, "downpayment" is never a triggering term.

Reason #2 - "downpayment" can't be a triggering term unless a downpayment is actually required.

First published on 02/10/2014

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