An MLO posts on social media: 'Buy with just $2,000 down this month.' Under Regulation Z, what else must the post disclose?
A stated down payment amount is a triggering term, requiring disclosure of the down payment, terms of repayment and the APR (and any rate increase after consummation) (12 CFR 1026.24(d)). Social-media posts promoting credit are advertisements. State law separately requires the NMLS ID. Source: 12 CFR 1026.24(d); CSBS/AARMR Model State Law, prohibited acts (as at 11 Oct 2026).
Assuming social-media posts are exempt from advertising rules.
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