We are looking at some new banner adds for our pre-paid card program and the banner ads don't include "Subject to Terms and Conditions." They do include a "Learn More" link which will bring them to our webpage which does detail our T&C. I'm used to requiring ads to include "Subject to Terms and Conditions" but I've seem some ads lately which don't include this verbiage and our marketing team is pushing back.

Our card is a simple load and spend card. No interest and no lending.

If there are no triggering terms in the banner, then Reg DD doesn't even require a one-click away to disclosures.

Whether you say subject to terms and conditions or learn more is a matter of semantics since neither are required.

Thanks Brian.

I'm tacking onto this thread since it's as close as I can find. We're also going to be placing banner ads for mortgage loans; however are unable to put the EHL logo on the banner. There will be a link to the mortgage page on our website that contains all requirements. Is this sufficient?

There are no one-click rules available for the EHL logo.

Thanks Randy - that's what I was afraid of.