Answer:
Answer by David Dickinson:Regulation Z allows for disclosures to be one click away. The Commentary to Sections 226.16(c) [open-end credit] and 226.24(d) [closed-end credit] state, ". . . A term triggering additional disclosures may be accompanied by a link that directly takes the consumer to the additional information".
Answer:
Answer by Richard Insley:Teaser rates cannot be more conspicuous than the APR. Even if the remaining advertising disclosures are linked, the APR must be on the banner with the teaser rate. (See Sections 226.16(d)(2) and 226.24(b)).
First published on BankersOnline.com 3/24/08
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