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#395928 - 08/03/05 04:14 PM Advertising Banner
MASS Banker Offline
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MASS  Banker
Joined: Sep 2004
Posts: 10
Boston MA
We are condsidering a banner that states "Sign up for direct deposit – get up to $100
Stop in today for details" In my opion the review of the FDIC regulations for advertising does not consider this an ad for a deposit account and would not require any additional disclosures. The banner would be attached to the building and would not require "Member FDIC". any comments or different opinions

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#395929 - 08/04/05 04:11 PM Re: Advertising Banner
David Dickinson Offline
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David Dickinson
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Posts: 18,762
Central City, NE
Point of clarification: You don't have to promote a deposit account to trigger the "Member FDIC" requirements. Read §328.3(a) where it states that ALL advertisements must include the official advertising statement, unless exempted in subparagraph (c).

Now to your specific scenario: I think you do need the "Member FDIC" statement. The exemption in §328.3(c)(3) that exempts "signs or plates . . . attached to the building" is intended to exempt the bank's name that is attached to the building announcing that this building is "XYZ Bank". Your banner is definitely an advertisement and I don't believe it qualifies for this exemption. Just my opinion.
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#395930 - 08/09/05 04:27 PM Re: Advertising Banner
Inquisitor / Sommelier Omega Offline
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A Grant Wood painting.
The marketing guy hands me a drive up poster with "Auto Loans as low as 5.5%". I know that I will need to footnote this as "2005 - 2006 Model Year, 60 months". Do I need to include a scenario as well?

I have a cheat sheet around here somewhere, but I just returned from vacation and can't find a basted thing.
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#395931 - 08/09/05 04:50 PM Re: Advertising Banner
David Dickinson Offline
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David Dickinson
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Central City, NE
First, Happy Birthday Omega!

Second: You'll need to reference "APR", not just say "5.5%".

Third: If you state "60 months" you trigger everything in §226.24(c)(2) [the amount of % of down payment, the terms of repayment and the APR].
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#395932 - 08/09/05 05:02 PM Re: Advertising Banner
Inquisitor / Sommelier Omega Offline
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A Grant Wood painting.
First, thank you.
Second, thank you.
If I keep it to "..as low as 5.5% APR" I don't trigger any additional disclosures? (Other than the FDIC / Equal Housing that I add to dang near everything.) I would like to keep it simple to avoid having people crashing into our building in an attempt to read the fine print.
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#395933 - 08/09/05 05:04 PM Re: Advertising Banner
John Burnett Offline
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Cape Cod
You can omit the FDIC logo/legend if it will save a life in your drive up. It's not needed on a loan-only ad.
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#395934 - 08/10/05 10:10 PM Re: Advertising Banner
Inquisitor / Sommelier Omega Offline
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Inquisitor / Sommelier Omega
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A Grant Wood painting.
"as low as 5.5% APR" is it? That is too simple John. The marketing guy may get suspicious.
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#395935 - 08/11/05 08:33 PM Re: Advertising Banner
John Burnett Offline
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John Burnett
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Cape Cod
Sometimes -- OK, rarely -- the regulation let's you get away with just a few words.
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#395936 - 09/02/05 03:42 PM Re: Advertising Banner
Anonymous
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Our bank is considering a banner on the outside of the building to advertise our savings account rate. The account has a minimum amount to open the account, but no minimum balance is required to obtain the advertised rate.

If the banner shows the product name, the abbreviation "APY" with the yield, and the term "annual percentage yield," and the words "Member FDIC," would this be sufficient?

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#395937 - 09/03/05 10:21 PM Re: Advertising Banner
David Dickinson Offline
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David Dickinson
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Central City, NE
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#395938 - 09/13/05 08:44 PM Re: Advertising Banner
Anonymous
Unregistered

I have one as well to just confirm. Banner only states "x.xx % APR" for new car loan promotion. Think we're ok there, but tent card states period of repayment (48-month car loan). APR is disclosed but must the bank also indicate an "example" of a payment schedule?

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#395939 - 09/14/05 02:12 PM Re: Advertising Banner
Jan94 Offline
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Joined: Mar 2001
Posts: 828
USA
Bump? Anyone?

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#395940 - 09/14/05 03:51 PM Re: Advertising Banner
John Burnett Offline
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Posts: 40,086
Cape Cod
As you might have guessed, the answer is different for the banner and for the tent cards. We could tell you the answer, but you'd miss the fun of looking it up HERE in Regulation Z, section 226.24(c).
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#395941 - 09/16/05 02:12 AM Re: Advertising Banner
Jan94 Offline
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Joined: Mar 2001
Posts: 828
USA
Thank you, I wasn't trying to be lazy. I did go back and read this section of Reg Z. I'm just trying to understand whether we needed an example of terms of repayment and how to word it. We decided to go with the "unit-cost" approach as indicated in the OSC.
Last edited by Brody; 09/16/05 02:13 AM.
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#395942 - 09/17/05 07:41 PM Re: Advertising Banner
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
You read that section of Reg. Z. It should have told you that merely having the APR on the banner does not trigger other ad requirements. But the mention of 48-months on the tent card does.
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