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#335269 - 03/18/05 01:56 PM Television ad disclosures
M&M Offline
Platinum Poster
Joined: Nov 2003
Posts: 530
Midwest
Is anyone aware of any industry standard on how long a television ad disclosure should/must be flashed up on the screen? For instance, for a HELOC, how long should you keep the full APR disclosure up for viewing? How big should the font size be, etc? Any thoughts are appreciated.

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#335270 - 03/18/05 03:23 PM Re: Television ad disclosures
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Read Comment #1 in both the Commentary to §226.16 and the Commentary to §226.24. These both discuss "clear and conspicuous" standards, but also say that there are no format rules (type size or placement in the ad).

I would not use the car dealership ads as an example of what to do. I can never read their small print.
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David Dickinson
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#335271 - 03/18/05 04:21 PM Re: Television ad disclosures
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
It's very interesting that the current version of the bankruptcy revision legislation that's wending its way through Congress includes some TIL "tweaks." One of them would mandate that the Fed do what it failed to do on its last try: define "clear and conspicuous" for the purposes of TIL.

No matter what the Fed ultimately does or says, I'm not sanguine about the prospects that automobile ads (or any other TV ad except those from a financial institution) will become clearer or more conspicuous. There simply are no teeth in enforcement except from the financial institutions' regulators.
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BankersOnline.com
Fighting for Compliance since 1976
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