If we advertise our mortgage rate and terms on an outside banner, and it triggers the extra disclosures, do we have to list the assumptions on the banner? It seems obvious a car driving by will not be able to read the entire sign, but is that what the regulation requires? We do have our phone number listed... would it be better to say "for details call xxx"?

The regulation does not provide for a "shorthand" disclosure of required information on outdoor banners, signs, etc. If you don't want to include the expanded verbiage, omit the trigger terms. And don't forget the EHL or EHO logotype (including both the graphic and the words).

John Burnett,

I was researching banner exemptions - the kind you hang outside...

Resurrecting this a bit. So then, in the case of a home secured HELOC Promotion period, when referencing 1026.16 (d)(6)(iii) it says, "Envelope Excluded. The requirements of para. (d)(6)(ii) of this section do not apply to an envelope in which an application or solicitation is mailed, or to a banner advertisement or pop-up advertisement linked to an application or solicitation provided electronically."
I read this two different ways regarding the banner exemption - are they talking about banners on web pages or a banner that you can hang outside your door?

Based on the context in which the term "banner advertisement" is used, it's almost certainly a reference to electronic banners on web pages. You do raise an interesting question, however, because it's rare when Reg. Z does not define a significant term before using it.

Richard,
I appreciate your knowledge. I'm posing this question, because their poor use of English confuses me. If they wanted a banner to mean an electronic one, they would have not used the word 'advertisement' 2x in the same sentance. It would be more clear if they said, "...or to a banner or pop-up advertisement linked to an app...." But I agree the electronic context is there. I hate making decisions based on how I feel about context. But yes, a definition of banner would have been good! Maybe physical banners are referenced in some other "what we really meant" document. Happy fishing and thanks!

Since there is no provision in the Reg Z advertising rules for exceptions from those rules in the case of billboards or banners or other things that go bump in the night, I think you really have to look at the context in the language you have cited and realize it's referring to banner ads on websites.

Add this to the (very) short list of times you wished Reg. Z was longer and contained greater detail!