A monthly payment on your financing page triggers four more disclosures
Four credit terms turn a financing page into a regulated advertisement, and any one of them pulls in the whole disclosure set. Here is the list, the table the rule allows you to build instead, and the version that triggers nothing.
The fastest way for a home services or solar website to break a rule nobody mentioned is to put a monthly payment on the financing page. Under Regulation Z, at 12 CFR 1026.24, certain credit terms in an advertisement trigger a required set of disclosures alongside them.
The four triggers and the three disclosures
| If the page states | It must also state |
|---|---|
| The amount or percentage of any downpayment | The amount or percentage of the downpayment |
| The number of payments or period of repayment | The terms of repayment over the full term, including any balloon payment |
| The amount of any payment | The annual percentage rate, using that term |
| The amount of any finance charge | And if the rate may increase after consummation, that fact |
In plain terms: the moment a page says new system from 99 dollars a month, it has taken on the rest. The regulation does allow an electronic advertisement to carry the required terms in a single table, referenced from the places credit terms are mentioned, which is usually the cleanest way to build it and the one that survives a redesign.
The version with no risk at all
A page that says financing available, explains the process, and links to the lender's own page triggers nothing, because it states none of the four terms. Plenty of contractors do exactly that, deliberately. It costs a little persuasion and removes an entire category of exposure, and it also removes the maintenance problem: a payment example goes stale when rates move, and nobody remembers which page it was on.
If the figures stay, give them an owner and a review date, and build the disclosure as a component rather than as copy inside one page. The vertical versions are on our HVAC page and solar page.
