Compliance · Disclosures
Regulation Z Trigger Terms
Also known as: Reg Z trigger terms, TILA triggering terms, Truth in Lending advertising rules
Trigger terms are the specific credit terms that, once stated in a mortgage advertisement, force Regulation Z to require a full set of additional cost disclosures alongside them. Regulation Z names four triggering terms for closed-end credit at 12 CFR 1026.24(d)(1): the amount or percentage of any downpayment, the number of payments or period of repayment, the amount of any payment, and the amount of any finance charge. Home-equity lines run on a separate and broader list at 1026.16(d), where negative statements count too. The advertising rules bind everyone who advertises consumer credit, not only the creditor.
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What counts as a trigger term
Regulation Z lists four triggering terms for closed-end credit at 12 CFR 1026.24(d)(1). A term counts even when it is not stated outright. Comment 24(d)-1 gives the example of an advertisement stating "80 percent financing available," which is in fact indicating that a 20 percent downpayment is required.
| Statement in the ad | Trigger under 1026.24(d)(1)? | Cite |
|---|---|---|
| "Only 5% down," "as low as $100 down," "total move-in costs of $800" | Yes. The amount or percentage of any downpayment. By virtue of the definition of downpayment in 1026.2, this trigger is limited to credit sale transactions | 1026.24(d)(1)(i); comment 24(d)(1)-1.i |
| "30-year mortgage," "48-month payment terms," "repayment in as many as 36 monthly installments" | Yes. The number of payments or period of repayment | 1026.24(d)(1)(ii); comment 24(d)(1)-2.i |
| "$500,000 loan for just $1,650 per month," "$25 weekly," "$1,200 balance payable in 10 equal installments" | Yes. The amount of any payment, including where the amount is readily determinable rather than stated | 1026.24(d)(1)(iii); comment 24(d)(1)-3.i |
| "$500 total cost of credit," "$50,000 mortgages, 2 points to the borrower" | Yes. The amount of the finance charge or any portion of it | 1026.24(d)(1)(iv); comment 24(d)(1)-4.i |
| A stated annual percentage rate on its own, such as "6.5% APR" | No. Statements of the annual percentage rate are not triggering terms. The separate rate rule in 1026.24(c) still applies | comment 24(d)(1)-4.ii |
| "No closing costs" | No. A statement that there is no particular charge for credit is not a triggering term | comment 24(d)(1)-4.ii |
| "No downpayment," "no trade-in required" | No. The downpayment trigger applies only if a downpayment is actually required | comment 24(d)(1)-1.ii |
| "Monthly payments to suit your needs," "regular monthly payments" | No. These are not deemed to be statements of the amount of any payment | comment 24(d)(1)-3.ii |
| "Pay weekly," "monthly payment terms arranged," "take years to repay" | No. These do not indicate a time period over which a loan may be financed | comment 24(d)(1)-2.ii |
What a triggering term forces into the ad
Once any of the four appears, 1026.24(d)(2) requires the following terms, as applicable. The rule permits an example of one or more typical extensions of credit stating all the terms applicable to each, provided the examples are labeled as such and reflect representative credit terms the creditor actually makes available.
| Required disclosure | Detail | Cite |
|---|---|---|
| Downpayment | The total downpayment as a dollar amount or percentage. The word "downpayment" need not be used. "10% cash required from buyer" suffices | 1026.24(d)(2)(i); comment 24(d)(2)-1 |
| Terms of repayment | Repayment obligations over the full term of the loan, including any balloon payment, not just the terms that apply for a limited period. Where a lower payment series is followed by a higher one, state the number and time period of each series and the amount of each, assuming the consumer makes the lower payments for the maximum allowable period | 1026.24(d)(2)(ii); comment 24(d)(2)-2 |
| Balloon payment | If a balloon payment results when the consumer makes only the minimum payments, state its amount and timing with equal prominence and in close proximity to the minimum payment statement | comment 24(d)(2)-3 |
| Annual percentage rate | The rate stated as the "annual percentage rate," using that term, which may be abbreviated APR, plus the fact that the rate is subject to increase after consummation where that applies | 1026.24(d)(2)(iii); comment 24(d)(2)-4 |
| Terms you can actually deliver | An advertisement that states specific credit terms may state only those terms that actually are or will be arranged or offered by the creditor. Advertising a very low annual percentage rate that will not in fact be available at any time is prohibited | 1026.24(a); comment 24(a)-1 |
The rate rule applies whether or not anything is triggered
1026.24(c) governs any advertisement that states a rate of finance charge, including advertisements that contain no triggering term at all. The rate has to be stated as an "annual percentage rate," using that term, and the abbreviation APR is permitted. If the annual percentage rate may be increased after consummation, the advertisement has to state that fact, though it need not describe the increase, its limits, or how it would affect the payment schedule.
For credit secured by a dwelling, the advertisement may not state any other rate, except that a simple annual rate applied to an unpaid balance may appear in conjunction with, but not more conspicuously than, the annual percentage rate. A simple annual rate for this purpose is the rate at which interest is accruing, so an effective rate, a payment rate, or a qualifying rate does not qualify.
Extra rules for closed-end credit secured by a dwelling
1026.24(f) adds a second layer for credit secured by a dwelling. It applies to any such advertisement other than television or radio advertisements, and it reaches promotional materials that accompany applications.
| Situation | What 1026.24 requires | Cite |
|---|---|---|
| The ad states a simple annual rate and more than one simple annual rate will apply over the term | Disclose each simple annual rate that will apply, the period during which each applies, and the annual percentage rate for the loan. In variable-rate transactions a rate determined by adding an index and margin is disclosed on a reasonably current index and margin | 1026.24(f)(2)(i) |
| The ad states the amount of any payment | Disclose the amount of each payment that will apply over the term including any balloon payment, the period during which each applies, and, in an advertisement for credit secured by a first lien, the fact that payments do not include amounts for taxes and insurance premiums and that the actual payment obligation will be greater | 1026.24(f)(3)(i) |
| Prominence and placement | Required rate and payment information in the same type size as the advertised rate or payment is deemed equally prominent. Information immediately next to, directly above, or directly below the advertised rate or payment, with no intervening text or graphical displays, is deemed closely proximate. A footnote does not qualify | comment 24(b)-2; comment 24(f)-2 |
| How current the index and margin have to be | In effect within 30 days before the advertisement is viewed by the public on a website, within 30 days before printing for general-circulation print, or within 60 days before mailing for direct mail | comment 24(f)-6 |
| Envelopes, banners and pop-ups | 1026.24(f)(2) and (f)(3) do not apply to a mailing envelope, or to a banner or pop-up advertisement linked to an application or solicitation provided electronically. The 1026.24(d)(2) disclosures are not excluded | 1026.24(f)(4) |
Seven acts prohibited outright in dwelling-secured advertising
1026.24(i) bans seven practices in advertisements for credit secured by a dwelling. These are conduct rules rather than disclosure rules, so no added line of copy cures them. This is where Regulation Z overlaps most directly with Regulation N (MAP Rule).
| Prohibited act | What it covers | Cite |
|---|---|---|
| Misleading advertising of "fixed" rates and payments | Using "fixed" to refer to rates, payments, or the transaction in an ad for variable-rate transactions or other transactions where the payment will increase, unless "Adjustable-Rate Mortgage," "Variable-Rate Mortgage," or "ARM" appears before the first use of "fixed" and at least as conspicuously, and each use of "fixed" carries an equally prominent and closely proximate statement of the period it is fixed for and the fact that the rate may vary or the payment may increase after that period | 1026.24(i)(1) |
| Misleading comparisons | Comparing actual or hypothetical credit payments or rates with any payment or simple annual rate available for less than the full term, without a clear and conspicuous comparison to the 1026.24(f)(2) and (f)(3) information. A claim such as "save $300 per month on a $300,000 loan" is an implied comparison with the consumer's current payment | 1026.24(i)(2); comment 24(i)-1 |
| Misrepresentations about government endorsement | Stating that the product is a "government loan program," a "government-supported loan," or is otherwise endorsed or sponsored by a Federal, state, or local government entity, unless it is an FHA loan, VA loan, or similar program that in fact is | 1026.24(i)(3) |
| Misleading use of the current lender's name | Using the name of the consumer's current lender in an ad not sent by or on behalf of that lender, unless the ad discloses the advertiser's own name with equal prominence and includes a clear and conspicuous statement that the advertiser is not associated with, or acting on behalf of, the consumer's current lender | 1026.24(i)(4) |
| Misleading claims of debt elimination | Misleading claims that the product will eliminate debt or result in a waiver or forgiveness of the consumer's existing terms with or obligations to another creditor. The commentary's examples include "Wipe-Out Personal Debts!" and "Refinance today and wipe your debt clean!" Legitimate statements that the product may reduce debt payments, consolidate debts, or shorten the term of the debt are not covered | 1026.24(i)(5); comment 24(i)-3 |
| Misleading use of the term "counselor" | Using "counselor" to refer to a for-profit mortgage broker or creditor, its employees, or people working for the broker or creditor who are involved in offering, originating or selling mortgages | 1026.24(i)(6) |
| Misleading foreign-language advertisements | Giving some trigger terms or required disclosures, such as an initial rate or payment, only in a foreign language while giving others, such as the fully-indexed rate or fully amortizing payment, only in English in the same advertisement | 1026.24(i)(7) |
HELOCs run on a different and broader trigger list
A home-equity line of credit is open-end credit, so 1026.24 does not reach it. Comment 16(d)-8 is explicit that advertisements for home-equity plans are governed solely by the requirements in 1026.16, except 1026.16(g), and not by the closed-end advertising rules in 1026.24. The open-end trigger list is wider in one way that catches marketers out: negative statements trigger it.
| Question | Closed-end mortgage, 1026.24 | Home-equity plan, 1026.16(d) |
|---|---|---|
| What sets off the additional disclosures | Four terms: the downpayment amount or percentage, the number of payments or repayment period, the amount of any payment, and the amount of any finance charge | Any term required to be disclosed under 1026.6(a)(1) or (a)(2), or the payment terms of the plan, set forth affirmatively or negatively |
| Do negative statements count | No. "No downpayment" and "no closing costs" are not triggering terms | Yes. "No annual fee," "no points," and "we waive closing costs" each require the additional information. "Low fees" does not |
| What has to be added | The downpayment, the terms of repayment over the full term including any balloon payment, and the annual percentage rate with the variable-rate notice | Any loan fee that is a percentage of the credit limit plus an estimate of other fees to open the plan as a single dollar amount or reasonable range, any periodic rate used to compute the finance charge expressed as an annual percentage rate, and the maximum annual percentage rate in a variable-rate plan |
| Using the word "fixed" | 1026.24(i)(1) sets the ARM-labelling and time-period conditions | 1026.16(f) bars calling an annual percentage rate "fixed" unless the ad specifies a time period the rate will be fixed and will not increase during, or, absent a period, states the rate will not increase while the plan is open |
| Named prohibitions | The seven acts in 1026.24(i) | A home-equity plan may not be called "free money" or described with a similarly misleading term. "No closing costs" or "we waive closing costs" is out if consumers may be required to pay any closing costs, such as recordation fees |
| Balloon payments | Amount and timing, with equal prominence and in close proximity to the minimum payment statement | Same, at 1026.16(d)(3), and the ad must also state that a balloon payment may result even where that outcome is uncertain or unlikely |
Channel: what the disclosure has to look like
Regulation Z prescribes no type size and no fixed location. Comment 24(b)-1 says the credit terms need not be printed in a certain type size nor need they appear in any particular place in the advertisement. The format rules that do exist are the equal-prominence and close-proximity rules for dwelling-secured rates and payments, plus the channel standards below.
| Channel | What the disclosure has to look like | Cite |
|---|---|---|
| Landing page or long-form web article | Not obscured by techniques such as graphical displays, shading, coloration, or other devices. If the required terms sit in a table or schedule elsewhere, any trigger term appearing elsewhere must clearly direct the consumer to the location where that table begins, for example through a link that takes the consumer straight to it | comment 24(b)-3; 1026.24(e); comment 24(e)-4 |
| On-screen text in a video | Displayed in a manner that allows a consumer to read the information, and not obscured. Very fine print fails the standard where consumers cannot see and read what is required | comment 24(b)-4 |
| 30-second television or radio spot | Either state each 1026.24(d)(2) disclosure clearly and conspicuously, or state the annual percentage rate information and list a toll-free number with accompanying language such as "call 1-(800) 000-0000 for details about credit costs and terms." The 1026.24(f) rate and payment rules do not apply to television or radio | 1026.24(g); comment 24(g)-2; 1026.24(f)(1) |
| Voiceover, podcast read, or livestream | Given at a speed and volume sufficient for a consumer to hear and comprehend them. The oral standard is written for radio, television, or other medium, so a livestream is inside it | comment 24(b)-5 |
| Social post caption | The post is a commercial message that promotes a credit transaction, so it is an advertisement on its own. A caption stating a payment amount carries the 1026.24(d)(2) set with it, or a link that takes the viewer directly to the table of terms | 1026.2(a)(2); 1026.24(e); comment 24(e)-4 |
| Banner or pop-up linked to an application | Exempt from the 1026.24(f)(2) and (f)(3) rate and payment disclosures. Not exempt from 1026.24(d)(2) | 1026.24(f)(4) |
One gap is worth naming. Regulation Z does not define "television advertisement," and an on-demand video posted to a website or a video platform does not clearly sit inside the term. Whether a piece of video content can use the alternative toll-free-number route in 1026.24(g) is a call for the client's compliance function, not for the production team.
What this means for your marketing
A payment figure in the hook is the most expensive number in the script. Naming a monthly payment triggers the full 1026.24(d)(2) set, and on a dwelling-secured loan it also triggers 1026.24(f)(3): every payment that will apply over the term, the period each applies for, and, on a first-lien ad, the statement that payments exclude taxes and insurance and the real obligation will be greater. That is a long superimposition to fit against a fast cut, so decide before the shoot whether the number earns its place.
Rate-only creative stays outside the trigger rules. A statement of the annual percentage rate is not a triggering term. Creative built around the rate, the process, or the loan type carries 1026.24(c) and, where more than one simple annual rate will apply over the term, 1026.24(f)(2), without pulling in the downpayment and repayment-terms block.
A footnote does not satisfy close proximity. Comment 24(f)-2 treats information as closely proximate when it sits immediately next to, directly above, or directly below the rate or payment, and it says a footnote does not qualify. For dwelling-secured rate and payment claims that rules out the familiar pattern of a clean lower third with the detail parked on an end card.
Your agency is a person under these rules. Comment 2(a)(2)-2 says all persons must comply with the advertising provisions in 1026.16 and 1026.24, not just those that meet the definition of creditor, and it names home builders, merchants, and others as examples. Section 145 of the Act shields the owner and personnel of the medium in which the ad appears from civil liability. That exemption covers the media owner and does not extend to the agency that produced the ad.
Rate creative expires on its own clock. An index and margin is only reasonably current if it was in effect within 30 days before a web page is viewed by the public, within 30 days before printing, or within 60 days before a direct mailing. An evergreen video carrying a specific variable rate goes stale without anyone touching it, so build the number to be swapped or leave it out of the master.
Regulation Z is not the only rule on the page. Regulation N (MAP Rule) bans material misrepresentation about any term of a mortgage credit product outright, whether or not a trigger term appears, so it reaches claims Regulation Z never touches. RESPA Section 8 governs the co-marketing arrangement behind a piece of content, since no person may give or accept a fee, kickback, or other thing of value for the referral of settlement service business. Regulation DD applies instead where the same institution advertises a deposit account, where the rate has to be stated as an annual percentage yield.
What this looks like in a script
Two triggers in one line. "30-year" is a period of repayment under 1026.24(d)(1)(ii) and "$1,650 a month" is the amount of a payment under 1026.24(d)(1)(iii). On a dwelling-secured loan the payment also pulls in 1026.24(f)(3).
1026.24(i)(1) sets the conditions on the word "fixed" in dwelling-secured advertising for variable-rate transactions and for any transaction where the payment will increase.
Comment 24(i)-1 treats a claim about the amount a consumer may save as an implied comparison between the advertised product's payment and the consumer's current payment, which brings 1026.24(i)(2) into play.
1026.24(i)(4) permits the current lender's name only with equal-prominence self-identification and the non-association statement.
Common questions
Primary sources
- 12 CFR 1026.24, Advertising (closed-end credit)full rule text, including the trigger terms at (d)(1) and the prohibited acts at (i)
- 12 CFR 1026.16, Advertising (open-end credit and home-equity plans)the HELOC trigger list at (d) and the "fixed" rule at (f)
- Supplement I to Part 1026, Official Interpretationscomments to 1026.24 and 1026.16(d), which carry most of the worked examples
- 12 CFR 1026.2(a)(2), definition of advertisementcomment 2(a)(2)-2 extends 1026.16 and 1026.24 to all persons, not only creditors
Related terms
Daniel Schoester
Founder & CEO
Daniel Schoester combines years of SEO obsession with financial know-how. After receiving an Honours Bachelor of Business Administration (Finance), Daniel began working at a prominent mortgage website, where his content quickly quadrupled monthly traffic to over one million views.
Building on this success, Daniel launched Croton Content to help clients scale through evergreen content assets — notably working with Forbes Advisor, Moneywise, and Hardbacon.
In 2024, Daniel expanded his focus to YouTube after studying Google’s algorithm changes. He noticed YouTube’s increasing alignment with search visibility compared to traditional written SEO content — plus its ability to generate passive revenue and long-term brand authority.
Educational information only. This is not legal or compliance advice. Confirm current requirements with your compliance officer and the primary sources above.
Last reviewed: 10 September 2026 · Reviewed against the text of 12 CFR 1026.24, 1026.16 and 1026.2 and the Official Interpretations in Supplement I to Part 1026.