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#2191001 - 08/29/18 02:37 PM Television Ad-Rate Tiers
Bec Offline
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Bec
Joined: Jul 2010
Posts: 1,114
The Great White North
We are advertising a product that has rate tiers. The executives want to advertise the highest tier, of course, with the best rate. It is the tier that requires $1MM for a balance. First question, the tier is disclosed as a slide in the ad. There is the APY in, for example, 20 point font and the $1MM required balance is in, for example, 10 point font. Firstly, I believe that the $1MM balance requirement must be the same size as the APR, am I right?

Also, does it seem a little UDAAPish to advertise that particular tier? It isn't commensurate with the demographic and I could see Joe Schmo watching his TV, seeing that great rate, not realizing the 1MM balance, coming into open the account and thinking he got the old bait and switch.

Finally, on this slide, there is disclosure language that lists the other tiers as I have ascertained that requirement is not excluded in the TV ads. at least on the checklist I saw. The slide is on the screen for about 2 seconds. Is that disclosure ok, or would the "please stop in and see us" blurb be enough?
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#2191026 - 08/29/18 03:28 PM Re: Television Ad-Rate Tiers Bec
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,632
From the commentary to Regulation DD:
"1. Tiered-rate accounts. An advertisement for a tiered-rate account that states an annual percentage yield must also state the annual percentage yield for each tier, along with corresponding minimum balance requirements. Any interest rates stated must appear in conjunction with the applicable annual percentage yields for each tier."
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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