Yes, you should provide additional disclosures on advertisements using the terms “Prime Floating,” “Prime Minus xx.xx%,” or “X Year Term.” Unlike Regulation X, Regulation Z does not provide exceptions or permit short-form advertising disclosures for banners or scrolling digital signs.

Regulation Z’s rules for home-equity plans require additional disclosures when an advertisement uses a trigger term, such as the finance charge. The additional disclosures are required, even if the trigger term is stated implicitly, if the trigger term “may be readily determined from the advertisement.” Because the finance charge could be readily determined from the statements “Prime floating” or “Prime Minus xx.xx%,” both statements trigger the additional advertising disclosures required for home-secured plans under § 1026.16 (under both subsections (b) and (d)).

Another trigger term is the “payment terms of the plan,” such as a statement of the length of the plan. Consequently, stating an “x year term” also will trigger the additional advertising disclosures required for home-secured plans.

• Regulation Z, 12 CFR 1026.16(b)(1) (“Any term required to be disclosed under § 1026.6(a)(1) or (a)(2) [including a statement of the finance charge] set forth affirmatively or negatively in an advertisement for a home-equity plan subject to the requirements of § 1026.40 triggers additional disclosures under this section.”)

• Regulation Z, 12 CFR 1026.16(d)(1) (Even more additional advertising disclosures are triggered “if any of the terms required to be disclosed under § 1026.6(a)(1) or (a)(2) [including a statement of the finance charge] or the payment terms of the plan are set forth, affirmatively or negatively, in an advertisement for a home-equity plan subject to the requirements of § 1026.40 . . . .”)

• Official Interpretations, 12 CFR 1026, Paragraph 16(b)(1), Comment 2 (“Section 1026.16(b) applies even if the triggering term is not stated explicitly, but may be readily determined from the advertisement.”)

• Official Interpretations, 12 CFR 1026, Paragraph 16(d)(1), Comment 1 (“References to payment terms include references to the draw period or any repayment period, to the length of the plan, to how the minimum payments are determined and to the timing of such payments.”)