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A mortgage company's billboard displays 'Refinance and save! Payments starting at $999 per month on loans up to $200,000.' What makes this advertisement non-compliant with TILA?

Correct Answer

C) It states a payment amount without disclosing the APR

Under TILA Regulation Z Section 1026.24, stating a specific payment amount ('$999 per month') is a triggering term that requires disclosure of the APR. The loan amount mentioned ($200,000) is not itself a triggering term, but the payment amount triggers the APR disclosure requirement.

Answer Options
A
It doesn't specify the loan term for the payment amount
B
It mentions a specific loan amount without disclosing the APR
C
It states a payment amount without disclosing the APR
D
It uses the word 'save' without quantifying the savings

Why This Is the Correct Answer

Under TILA Regulation Z Section 1026.24, stating a specific payment amount ('$999 per month') is a triggering term that requires disclosure of the APR. The loan amount mentioned ($200,000) is not itself a triggering term, but the payment amount triggers the APR disclosure requirement.

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