Would an advertisement offering acreage with a specific down payment violate the Truth in Lending Act?

The Truth in Lending Act (TILA) is designed to promote informed use of consumer credit by requiring disclosures about its terms and cost. It primarily applies to credit transactions where the credit is extended to consumers. Under Regulation Z, which implements TILA, certain exemptions exist, including ones related to private sellers or owners who are not engaged in the business of lending money.

When considering the advertisement of acreage with a specific down payment, if the seller is an owner of the property and not a lender or a broker acting in a commercial capacity, they would not fall under the regulations set by TILA. Therefore, an advertisement from a private owner specifying a down payment may not violate TILA because the owner is not covered by Regulation Z requirements, which are aimed at commercial transactions rather than those conducted by individuals selling their own property.

This understanding clarifies why the assertion that owners are not covered by Regulation Z is ultimately the correct focus in this scenario.