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#2178835 - 05/18/18 08:16 PM Message on Hold
JoAnne Offline
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Joined: Feb 2001
Posts: 795
Michigan
Are there any specific disclosure requirements if you have an advertisement for a product or service playing on the "message on hold" feature. (Member FDIC, EHL, etc.)?
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#2178844 - 05/18/18 08:52 PM Re: Message on Hold JoAnne
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Only those that are required on any advertisement.
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#2178859 - 05/18/18 10:47 PM Re: Message on Hold JoAnne
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 10,179
Toano, VA
Round up all the usual suspects.
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#2181319 - 06/11/18 08:31 PM Re: Message on Hold JoAnne
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
And, please, don't even think about applying the exclusion for "Member FDIC" for under-30-second ads. That exclusion is only available for TV and radio (broadcast) ads. Not for message-on-hold, not for videos on your website, and not for a TV screen in the lobby that scrolls ads while the customer waits in the teller queue.
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#2182752 - 06/22/18 03:09 PM Re: Message on Hold John Burnett
CloudShape Offline
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CloudShape
Joined: Oct 2002
Posts: 525
Edge of Sanity
I have a different question on the message on hold - if we provide a service through a third party that uses trademarked applications, do we need to state "ABC is a trademark of XYZ Corporation" in the message on hold?

For example, Apple Pay. Our customers can use Apple Pay through the mobile wallet of our third party provider. If we are promoting this on the message on hold, do we also need to include that Apple Pay is a trademark of Apple, Inc, registered in the US and other countries? I know we include that language in the mousetracks on print ads and also in radio and TV ads, but those are generally longer advertisements. For the message on hold, we want it briefer (because customers don't want to listen to a 30 - 60 second spiel on hold) and adding the trademark disclosure, along with the other disclosures, makes that message quite lengthy. We would prefer to not have it in the message on hold.

I have looked for regulation/law regarding this and am coming up empty so far. I have also asked for someone to check the contract with our third party provider to see if it addresses how it should/must be advertised.

Any other thoughts? Can someone point me toward regulation/law on this?
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#2182760 - 06/22/18 03:21 PM Re: Message on Hold JoAnne
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Use of Apple Pay in a manner that is not approved by Apple is going to get you sued by them. It is not a law or regulatory issue. You need to research the Apple Pay advertising requirements.
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#2182766 - 06/22/18 03:39 PM Re: Message on Hold rlcarey
CloudShape Offline
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CloudShape
Joined: Oct 2002
Posts: 525
Edge of Sanity
Thank you.
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