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#2243884 - 10/09/20 07:54 PM TV Spot
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
I've been asked to look over our first TV AD. Besides the reference to FDIC insurance, Visa (Our partner) and the general T&Cs are there are any disclosures that need to be included? The product is a prepaid card with no interest involved.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#2243895 - 10/09/20 09:27 PM Re: TV Spot ACBbank
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,716
Illinois
A prepaid card may be considered an account under Reg DD, but the only triggering terms in Reg DD are an APY disclosure (not applicable if not interest bearing) and bonus disclosure so unless you are providing something in excess of $10 in value for opening, renewing, maintaining or adding funds to a prepaid card, that would not be applicable either.

Look at 1030.8 for the requirements you'd need to consider.

Also review the language in the ad for anything that could be considered confusing or misleading as UDAP always applies even if there are no triggering terms in an ad.
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#2243897 - 10/09/20 09:51 PM Re: TV Spot ACBbank
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
Thanks Brian.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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