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#2185968 - 07/18/18 08:05 PM Reg DD Advertising CDs in Newspapers
NU Rhules Offline
Gold Star
NU Rhules
Joined: Mar 2011
Posts: 473
SE, Nebraska
Does Reg DD or it's Commentary allow for a banner ad (bottom of newspaper page 1) to say, "Get our 1 year CD x.xx% APY, See page 3 for details", and then include all the details in the Page 3 ad? Or is the only option to keep the two ads "separate" and not mention the rate on page one, but include it along with all the details on page 3? I've searched the internet and this forum and can find no similar discussion. Seems the regulation should allow for these kinds of banner ads since they are in such common use.

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Operations Compliance
#2186165 - 07/19/18 08:18 PM Re: Reg DD Advertising CDs in Newspapers NU Rhules
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I don't believe so. Reg DD does allow disclosures to be "1 click away" but that is for electronic marketing. I agree this is the same, but it's technically not allowed (in my opinion).
_________________________
David Dickinson
http://www.bankerscompliance.com

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#2186210 - 07/20/18 12:30 PM Re: Reg DD Advertising CDs in Newspapers NU Rhules
NU Rhules Offline
Gold Star
NU Rhules
Joined: Mar 2011
Posts: 473
SE, Nebraska
As I expected. I agree with that position too. Thanks Mr. Dickinson.

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