Desert Ridge Dental: /patient-info/financing
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Description
Desert Ridge Dental · /patient-info/financing (NV). Merchant website, captured Oct 11, 9:40 PM. Closed-end installment loan (program agreement); 12 CFR 1026.24.
Findings · 0 of 4 decided
1. Regulation Z advertising · rate stated
"0% interest for 12 months"
A rate of finance charge is stated without the term "annual percentage rate." The rate must be stated as an annual percentage rate, using that term, and if it may increase after consummation the advertisement must say so.
· Regulation Z advertising requirements for consumer credit
2. Regulation Z advertising · triggering terms
"$125 per month" · "24 months"
A payment amount (1026.24(d)(1)(iii)) and a repayment period ((d)(1)(ii)) are stated. The downpayment, terms of repayment and annual percentage rate (1026.24(d)(2)(i)-(iii)) were not located.
; (d)(2)(i)-(iii) · Regulation Z advertising requirements for consumer credit
3. Regulation Z advertising · terms actually offered
"zero interest for the life of the financing plan"
Confirm against the creditor's program terms that these terms are actually arranged or offered. If they are not, the statement can't appear.
· Regulation Z advertising requirements for consumer credit
4. Deception standard · approval statement
"Get Approved—Almost Everyone Is!"
Review whether the statement is likely to mislead a reasonable consumer about a material term, judged by its overall net impression. A qualification counts only if it is clear and conspicuous.
; · UDAP, UDAAP
Tasks
F-2101 · Opened Oct 11 · CareBridge merchant websites v1