Skip to content
BOL Conferences
Thread Options
#1268427 - 10/16/09 08:22 PM See an employee for details....
E. Lavenza Offline
100 Club
Joined: Apr 2004
Posts: 111
laboratory
When can this statement be used in an advertisement? In other words, how much or how little info needs to be included before this can be added? When can this be used in place of all the mouse text? Thank you.

Return to Top
Marketing
#1268462 - 10/16/09 08:40 PM Re: See an employee for details.... E. Lavenza
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Varies by reg/requirement. You have to look at the specific triggers and required disclosure(s) for each.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

Return to Top
#1268725 - 10/19/09 12:03 PM Re: See an employee for details.... BrendaC
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
One place it can be used is on indoor signs advertising deposit products. However, the regulatory "handwriting on the wall" suggests that the use of "see an employee for details" in lieu of including info in ads is becoming less and less acceptable.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1268759 - 10/19/09 01:50 PM Re: See an employee for details.... John Burnett
E. Lavenza Offline
100 Club
Joined: Apr 2004
Posts: 111
laboratory
Thank you for your replies. One last question, please? Can it be used on a rate sheet instead of spelling out the criteria to get that rate?

Return to Top
#1269017 - 10/19/09 05:56 PM Re: See an employee for details.... E. Lavenza
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Reg DD spells out the specific info for deposit rate sheets that are provided to consumers. For commercial customers, you need to avoid being deceptive or misleading. I personally can't speak to lending rate sheets.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

Return to Top
#1269084 - 10/19/09 06:56 PM Re: See an employee for details.... BrendaC
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
A rate sheet is an ad. If it's available to consumers, it's an ad that has to comply with Reg DD and FDIC rules for deposit accounts; with Reg Z and Fair Lending rules for consumer loan ads. There is no "ask us for more information" provision in any of those rules.

I did miss the fact that Reg Z will have "ask us for details" provisions for some TV/radio ads as an option. But you just cannot do it when it comes to print advertising.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1269222 - 10/19/09 08:12 PM Re: See an employee for details.... John Burnett
E. Lavenza Offline
100 Club
Joined: Apr 2004
Posts: 111
laboratory
Thank you again. Based on your answers, I am not understanding those employee buttons with an APY and "ask us" language. Are you saying this doesn't work? I am looking for scenario when this does work for deposit rates.

Return to Top
#1271244 - 10/22/09 12:57 PM Re: See an employee for details.... E. Lavenza
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
A rate sheet can walk out the door with the customer, so it has to comply with the ad rules.

The employee buttons enjoy the carve-out for indoor signs. They would be technical violations if worn outside the bank office, but are OK as long as they stay within the branch walls.

In in-store branches where there are no walls that separate the branch of the bank from the host store, in-bank signs present some genuine questions.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  Andy_Z, MoneyMaker