There has been much discussion on this particular question within our institution. I am certain my Bankers Online group can help me out.
We would like to use this (similar) phrase in a social media post. No terms or rates mentioned.

'Bank with us for better rates on home, auto, and personal loans'.

Part of those involved in reviewing this state that full loan disclosures should be linked to the post. Part of those involved state that the only 'disclosure' needed would be the EHL logo - nothing further.

Any assistance you could provide to help in settling this debate (and proper disclosures made) would be greatly appreciated.

Thanks!

I don't know if your statement necessarily contains any triggering terms. Definitely need the EHL logo.

There is something I don't like about the word "better" though. It seems you are maybe not being truthful unless you ALWAYS give the better rate in every situation. UDAAP maybe???

Yea, I agree. If you use better, you'd "better" be sure you're offering the best rates out of your competitors.

I actually thought of it differently. My read of the better rates here was that if I have a deposit account with the bank then I would be getting better loan rates than I would otherwise.

I guess you can see the potential for different read of the advertisement but I would be curious what message you are intending to communicate?

I think the term "better" is quite subjective and while it isn't my preference because to us nit pickers the question we ask is, "better than what?" I personally won't get excited by "better" and I don't believe it is deceptive as to UDAP. You could easily say "bank with us for our better rates..." and that's because the bank has "good" rates for some customers and "better" rates for higher qualified borrowers.

I agree the EHL should be there because of the reference to home loans. National banks would also normally use this but the OCC hasn't replaced the requirement that was deleted many, many years ago.

Since you are not using trigger terms for Reg Z, there is no requirement for a link or disclosure at this point.

The next issue is the use of social media and having an understanding of the demographics that the ad will be targeted to. There was a Facebook SNAFU a few years ago that you absolutely must avoid.