We are updating our on hold music and are going to include some advertisements. I've looked at various resources and can't seem to answer my question. Do we need to have Member FDIC or Equal Housing Lender on each of these short on hold advertisements? Thanks for your help.

Here is an ask the guru reference to this topic from 2002.

On Hold Ads

I would follow the same rules that would apply if you ran the "on-hold" message as a radio ad.

I would have said the same thing... I was surprised to see the Guru answer.

Thank you guys. I was a bit surprised and confused at the Guru's answer. I think erring on the side of caution is the way to go in this regulatory environment. We were leaning towards that also, but wanted some reinforcement. Thanks again.

Wishful thinking doesn't make your on-hold ad a radio ad, so I think you have to forget about the 30-second exception. Rick's Guru response is 10 years old, and there's been a rewrite of the FDIC's regulation on advertising of membership since then.

An on-hold message is an ad, and it should conform to the requirements for inclusion of the "Member FDIC" and "Equal Housing Lender" tags for print ads, unless you can obtain a written opinion from the agency involved that it will allow you to treat it as a radio ad. I also suggest you avoid including deposit and non-deposit products in the same on-hold ad.

Strictly deposit products. We have included "Member FDIC" and "Equal Housing Lender", regardless of length, as you suggested. Thanks for all of the input.

There's no harm in including "Equal Housing Lender," but you don't need to unless you're doing housing-related ads, such as those for loan products.