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#1220755 - 07/22/09 08:10 PM Internet Advertising
ktac MITCH Offline
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ktac MITCH
Joined: May 2005
Posts: 1,813
Giant side of TX
I am in need of help from someone who has traveled this road.
We are considering placing "Banner Ads" for deposit products on the local newspapers website. I understand all the same triggering terms apply (ie APR spelled out / Terms for time acct / Min to open and earn int / etc)
My question is - can the banner ad have a section that says "Click here for details" and that takes them to the "fine print" disclosures?
OR - does all required info have to be in the banner ad?
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#1220894 - 07/22/09 10:48 PM Re: Internet Advertising ktac MITCH
'Lil Freak! Offline
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'Lil Freak!
Joined: Sep 2005
Posts: 10,596
The psych ward
A link to the disclosures would suffice.
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#1221407 - 07/23/09 05:30 PM Re: Internet Advertising ktac MITCH
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,068
Toano, VA
Even though you may not need to include a statement about deposit insurance, I'd try to find a spot for one on every deposit ad in any medium. After all, in these troubled economic times, that statement may be more interesting to a potential depositor than all the rest of your product/price message.
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#1222544 - 07/24/09 09:20 PM Re: Internet Advertising Richard Insley
Tryin-2-Comply Offline
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Joined: Apr 2003
Posts: 202
Hills of TN
can you tell me - why you believe adding a link would suffice to meet the requirements?

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#1222559 - 07/24/09 09:34 PM Re: Internet Advertising Tryin-2-Comply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,637
Galveston, TX
Commentary 230.8(a):

9. Electronic advertising. If an electronic advertisement (such as an advertisement appearing on an Internet Web site) 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.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1222561 - 07/24/09 09:36 PM Re: Internet Advertising rlcarey
Tryin-2-Comply Offline
100 Club
Joined: Apr 2003
Posts: 202
Hills of TN
Thanks so much!

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