12 CFR 1026.24(b) (Advertising) provides a general definition stating that closed-end loans must be clear and conspicuous. The official interpretation gets specific with what that means for loans secured by a dwelling. But what about unsecured loans? What is a good definition to apply in those cases. Should the closed end secured by a dwelling comments be cited as controlling as well? Should one resort to FTC definitions of clear and conspicuous that talk about prominence, placement, presentation, proximity? Or should one explore other areas such as case law?

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Comment 1 refers to Comment 2, but the general clear and conspicuous standards apply to all closed-end credit. There should be no reason to go to any FTC definitions.