Truth in Lending / Truth in Leasing
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01
Truth In Lending
The following information is offered to assist the dealer in complying with the Motor Vehicle Dealer Advertising Practices and Enforcement Regulations.
It is the dealer’s responsibility to become familiar with all provisions of the Federal Truth in Lending Act (Regulation Z) and to ensure dealership advertisements are in compliance with these Federal directives.
Lending "Trigger Terms"
If one of the following "Trigger Terms" is stated in the ad:
- amount or percentage of down payment (“0 Down” or “No Money Down” is not considered a trigger term)
- amount of payment
- number of payments
- period of repayment
- amount of finance charge (in dollars)
Then the following required disclosures are needed:
- amount or percentage of down payment
- terms of repayment (e.g. number amount and timing of payments)
- APR
(amount or % down) , (# of months) payments at ($) per (month,week,etc.) at (%) APR.
*APR by itself is not considered a trigger term but is a requirement in the disclosure
**All Disclosures must be clear and conspicuous
02
Truth In Leasing
The following information is offered to assist the dealer in complying with the Motor Vehicle Dealer Advertising Practices and Enforcement Regulations.
It is the dealer’s responsibility to become familiar with all provisions of the Consumer Leasing Act (Regulation M) and to ensure dealership advertisements are in compliance with these Federal directives.
If one of the following "Trigger Terms" is stated in the ad:
- amount of any payment
- a statement of any capitalized cost reduction or other payment required including “0” down or any negative amount before or at consummation or by delivery if delivery takes place after consummation.
Then the following required disclosures are needed:
- the transaction advertised is a lease
- the total amount due at the beginning of the lease
- whether or not a security deposit is required
- the number, amounts and due dates or periods of schedule payments under the lease
Lease. Total amount of ($) any payment due at the beginning of the lease. (Number) of payments at ($) per (Month,week,etc.). Whether or not a Security Deposit is required.
*All Disclosures must be clear and conspicuous
**The total amount due at the beginning of a lease must either (1) include taxes and state what the taxes are based on and that the taxes may vary by jurisdiction or (2) must exclude taxes and state that fact.