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#2241262 - 08/19/20 05:42 PM Advertising?
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A person calls into a bank's customer service line and says, "I'd like information on credit cards you have." Does any information the bank provides in response to that inquiry need to meet the advertising requirements of 1026.16?

A customer is on the phone with a customer service rep discussing a checking account. At the end of the call, the rep says, "I notice you don't currently have a credit card with us, would you like to hear about our credit cards?" Does information provided about the card in this scenario need to meet the requirements of 1026.16?

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Lending Compliance
#2241278 - 08/19/20 06:50 PM Re: Advertising? Working From Home
rlcarey Online
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Have you read the commentary to 1026.2(a)(2) Advertisement?
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#2241301 - 08/19/20 08:54 PM Re: Advertising? Working From Home
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Yes, that is what I'm seeking clarification on. :-) I believe that my second example above falls into (i) J. Communications promoting a new open-end plan or closed-end transaction. I hesitate to call it a telephone solicitation since the call was not initiated by us, but it could be.

In the first example, I do not think we are "promoting" the product, merely explaining the terms in a response to an oral inquiry. Nor do I think we are ":soliciting" the product via the telephone since we did not make contact and we are merely fulfilling a request for info from a consumer.

So I think the first example does not require adherence to the advertising requirements, but the second example does. Please correct me if I'm wrong.

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#2242702 - 09/18/20 02:57 PM Re: Advertising? Working From Home
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Does anyone have any further insight on this question? I'm still not totally clear. Thanks

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#2242714 - 09/18/20 03:56 PM Re: Advertising? Working From Home
rlcarey Online
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I agree
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#2242720 - 09/18/20 04:38 PM Re: Advertising? Working From Home
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Thanks for the feedback. The commentary isn't that clear to me.

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