Additional rate disclosures for ARM advertisements

NAFCU receives many questions about advertisements and trigger terms in the context of closed-end mortgage loans. Section 1026.24 of Regulation Z governs the advertising requirements for closed-end mortgage loans. Today’s blog will look at adjustable rate mortgages (ARMs) and a certain additional disclosure that may be triggered depending on the content of an ARM advertisement.

Trigger Terms and Additional Disclosures for All Closed-End Credit

Before we focus on ARMs, let’s examine the general trigger term and additional disclosure requirements that apply to all advertisements for closed-end credit under Regulation Z. Section 1026.24(d)(1) identifies four categories of terms that trigger additional disclosures in all closed-end credit advertisements:

“(i) The amount or percentage of any downpayment.

(ii) The number of payments or period of repayment.


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