Radio and television ads that use mortgage triggering terms

Mortgage ads can trigger extra disclosure duties by mentioning certain loan terms. Regulation Z applies these rules to advertisements for credit secured by a dwelling. Radio and television present a practical constraint: a spoken or brief audio-visual ad may not have room for every item. Section 1026.24(g) provides a limited alternative for those media; it is not a general exemption from advertising disclosures.

What makes a term a trigger

Under § 1026.24(d)(1), examples include the amount of a down payment, the number of payments or repayment period, the amount of any payment, and the amount of a finance charge. If an advertisement states one of these terms, § 1026.24(d)(2) generally requires additional information, including the repayment terms, the annual percentage rate, and whether the rate may increase after consummation, as applicable. The exact disclosure depends on which trigger appears and the credit terms advertised.

The radio and television alternative

For an advertisement made through radio or television, the creditor may satisfy the rule by stating the information required by § 1026.24(d)(2)(iii)—the amount or percentage of the down payment—and giving a toll-free telephone number or a number that permits collect calls to be reversed. The ad must refer consumers to that number for additional cost information. This is a specific alternative for the covered media and trigger-disclosure requirement.

What the phone alternative does not do

The alternative does not let an advertiser omit the required down-payment statement, provide an ordinary number that charges the caller, or leave consumers without a clear reference to the additional cost information. It also does not remove other applicable requirements, such as rules against misleading advertising or separate requirements for statements about rates. Analyze each advertised term under the applicable subsection instead of assuming every short ad qualifies.

Quick example

Suppose a radio ad says, “Put 5% down and make payments of $1,400 a month.” Those are triggering terms. The advertiser must meet the applicable additional-disclosure rule. For a qualifying radio ad, the § 1026.24(g) alternative requires the down-payment information and a toll-free or collect-call-reversal number, with a statement directing listeners to call for more cost information. Merely adding “call us” with a standard chargeable number would not describe the permitted alternative.

Exam approach

1. Spot a term listed in § 1026.24(d)(1).
2. Identify the additional terms ordinarily required by § 1026.24(d)(2).
3. If the ad is radio or television, test the specific § 1026.24(g) alternative: required down-payment information, qualifying phone number, and a reference to additional cost information.
4. Keep other advertising rules in view; this limited alternative does not waive them.

Key takeaway

A radio or TV mortgage ad using a triggering term can use a narrow phone-number alternative, but it still has to state the required down-payment information and direct consumers to a toll-free or collect-call-reversal number for additional cost information.

The general trigger rule still applies

For closed-end credit secured by a dwelling, Regulation Z identifies terms that can trigger additional advertising disclosures, including the amount or percentage of a down payment, the number of payments or repayment period, the amount of any payment, and the amount of finance charge. When an ad uses a trigger, the creditor generally must also state the required repayment terms, including the down payment, full repayment terms, and APR.

Section 1026.24(g) supplies a narrow alternative for a radio or television advertisement: state the required down-payment information and provide a toll-free telephone number or a collect-call-reversal number through which consumers can obtain the other required terms. This is a medium-specific route, not a general exemption from the trigger rules.

Apply the exception to the actual medium

The ad must actually be a qualifying radio or television advertisement. An internet video, social-media clip, podcast, or streaming placement should not automatically be treated as traditional radio or television; distribution and format matter. If the campaign combines broadcast and digital versions, review each asset and placement under the rule that applies to it.

The number must connect consumers to the required additional terms. A disconnected line, a number that only reaches a general switchboard, or a script that omits the relevant information undermines the point of the alternative. Make sure the business can answer calls during the campaign and retains the approved terms that representatives will provide.

Worked example and review checklist

A television ad says “$1,500 down” for a covered mortgage. That is a trigger term. The ad may use the broadcast alternative if it states the required down-payment information and gives the qualifying phone number for the other terms. If the same wording is placed in a social-media graphic, do not assume that including the phone number automatically substitutes for all disclosures.

Before launch, identify each triggering phrase, confirm whether the placement qualifies for the broadcast alternative, test the phone line, and train staff to provide the required terms accurately. Keep scripts consistent with the current offer and significant eligibility conditions. A correct phone number does not cure a term that is not actually available under §1026.24(a).

Common mistakes

One mistake is thinking every rate mention triggers the same list; §1026.24(d) specifies the relevant terms for closed-end ads. Another is using the broadcast alternative in print or online media without checking the rule. A third is failing to state a required item in the ad itself: the alternative still requires the specified down-payment information.

The exam answer should cite the trigger, identify the extra disclosure obligation, then explain the radio/TV alternative and its required phone access. Keep actual-availability and deceptive-advertising issues separate from the trigger calculation.

Additional boundary detail

A campaign owner should retain the final broadcast recording, placement schedule, phone number test, and the terms staff are authorized to provide. Check that the number is spoken clearly and appears in a format listeners can use. A short advertisement that cannot fit all terms may use the specific phone alternative when the statutory conditions are met; it cannot omit the down-payment information that the alternative still requires.