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#1173278 - 04/30/09 03:36 PM Creative advertsing!
#Just Jay Offline
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#Just Jay
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
We have a condo project which we now own, and have contracted with a develeoper to finish the project. Marketing wants to advertise (without any bank name mention) that the condo project has "12 month interest free financing available, call the developer!" They feel this should be fine since our bank is not anywhere in the advertising, and no further disclosure is required.

I feel no go because we control the content of the advertising regardless if our name is on the ad or not, and we will be the bank customers who express interest in this as will be directed to, via our developer.

Thoughts?
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#1173679 - 04/30/09 07:41 PM Re: Creative advertsing! #Just Jay
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,007
Toano, VA
Why not simply treat it as an advertisement and be done with it? The disclosures couldn't be simpler: For example--with a sale price of $10,000 and 0% APR financing, your downpayment will be $1,000 and you will make 12 monthly payments of $750.
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#1173694 - 04/30/09 07:51 PM Re: Creative advertsing! Richard Insley
#Just Jay Offline
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#Just Jay
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
I agree and that is what I am asking for.

The debate is, prove to me we have to do that, considering the scenario above.
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#1173702 - 04/30/09 07:55 PM Re: Creative advertsing! #Just Jay
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,007
Toano, VA
Section 226.2(a)(2) applies to everyone who has anything to do with a credit promotion. The message is an advertisement.

Section 226.24(d)(1)(ii) says that the the number of payments or period of repayment is a trigger term. "12 month financing" is the period of repayment.
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