Our website has a couple of boxes to promote products with special rates. One is a CD with an APY of 5.00%. We also have on the website a rates and disclosure page that has all required TISA disclosures for this product.

Question #1- TISA requires the term "APY" to be written out at least once in the "advertisement". Is this requirement fulfilled by the TISA disclosures on another page? In other words, is all of our website considered one "advertisement"?

Question #2- Do we need to have something like an asterisked notation to "please see the disclosures on our deposits rate page"? I know most ads show this, but my question is whether it is required or not.

From Reg. DD Official Staff Interpretations: "9. Electronic advertising. If an advertisement using electronic communication
displays a triggering term (such as a bonus or annual percentage yield) the advertisement
must clearly refer the consumer to the location where the additional required information
begins. For example, an advertisement that includes a bonus or annual percentage yield
may be accompanied by a link that directly takes the consumer to the additional
information."

and "e) Exemption for certain advertisements
(e)(1) Certain media
(e)(1)(i)
1. Internet advertisements. The exemption for advertisements made through
broadcast or electronic media does not extend to advertisements made by electronic
communication, such as advertisements posted on the Internet or sent by e-mail."

I'm conservative enough to view each web page as an individual advertisement, so I'd want any "clear reference" to require one, or at absolute most, two, mouse-click(s) to see.