Tell us
what you think
Our Sponsors
 |
Our Sponsors
|
Question & Answer
Question: We're having a debate about lobby boards and Regulation DD. I understand that If we maintain a board inside the lobby that lists products and rates, the board does not need to include all of the specific requirements in section 230.8. My concern is that our board can be seen from outside the bank. We have large windows and a glass door. There is not really any place to put the lobby board that cannot be seen from the outside if someone stands at the window and looks in. Does this make the lobby board one that is "facing out" for purposes of 230.8(e)?
Answer: Regulation DD creates two rules for lobby boards, depending on where and how the board is placed. A lobby board that is intended for viewing only inside the bank's lobby may state only the rate using the term "Annual Percentage Rate" and state no other rate. The board must also advise customers to contact a bank employee for further information about account terms. This permission to omit terms that would otherwise be triggered for purposes of advertising presumes that the triggered terms are readily available, either in brochures or through customer service staff.
The rule requires that ads facing out must contain the triggered terms. The implication is that an ad designed to be seen from the street is not readily supported with complete information the way a sign inside the lobby is.
Now for your problem. A fishbowl style lobby that can be easily viewed from outside raises the question of which way your lobby board is facing. As we understand the rule, even a fishbowl bank may have lobby boards. However, you may want to give attention to how and where these boards are placed. Their placement should be clearly intended for in-bank use and not for viewing from outside. We recommend that they be placed in locations that are not easily viewed from windows, placed at an angle to windows, or actually facing desks. We also recommend that you use a letter or type size that is not easily read from a distance. Using extra large letters would imply that you meant a customer standing outside to be able to read it.
Use common sense and try to carry out the purpose of the rule. If a customer wants to put their nose to the glass and peer at your lobby board after hours, that's ok. The communication is still in a context that implies that the information is supported by staff that can answer questions. However, if you place the board in the window or door of the bank facing out, you create the implication that it is complete by itself and is all that the customer needs to know. It then becomes a sign "facing out."
Copyright © 1996 Compliance Action. Originally appeared in Compliance Action, Vol. 1, No. 11, 7/96
Rate This Article
Current Rating For the Feature:
Content-type:text/html
File or Directory cannot be opened.
Default error message. |
|