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#459314 - 11/20/05 06:57 PM Compliance requirements - the "fine print"
lorimkt Offline
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Joined: Nov 2005
Posts: 8
MN
Wondering if anyone knows if there is a minimum typesize for "fine print" in ads and in collateral material -- I seem to remember being cited for an ad I did where the typesize of the "fine print" needed to be bigger.

Gracias for any help or any references to compliance regs!

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#459315 - 11/21/05 03:06 AM Re: Compliance requirements - the "fine print"
flaire Offline
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flaire
Joined: Sep 2005
Posts: 228
sw us
Reg. Z 226.16 for open end credit advertising. 226.24 for closed end advertising.
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#459316 - 11/21/05 11:09 PM Re: Compliance requirements - the "fine print"
Anonymous
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The "general rule" goes like this: can a normal person with normal vision reasonably read your disclosure at the size it will be when printed. For instance, your proof sheet may be fine, but if the ad will be reduced to two column-widths when printed... maybe not so much.

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#459317 - 11/22/05 02:14 PM Re: Compliance requirements - the "fine print"
Dance129 Offline
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Actually, if the print is less than a font size of 8, it will no longer be considered a disclosure and you will be in violation.

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#459318 - 11/22/05 04:17 PM Re: Compliance requirements - the "fine print"
Anonymous
Unregistered

SarMar - Can you provide a reference for the size 8 requirement?

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#459319 - 11/22/05 04:35 PM Re: Compliance requirements - the "fine print"
Dance129 Offline
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Dance129
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I do not have a direct reference. I just asked our auditors and that is the size that they consider to be "fair" for consumer to be expected to read the information.

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#459320 - 11/22/05 05:02 PM Re: Compliance requirements - the "fine print"
TXFacilitator Offline
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Posts: 136
TX
We just created all new brochures and that is the same thing we were told...font size 8

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#459321 - 11/22/05 05:52 PM Re: Compliance requirements - the "fine print"
'Lil Freak! Offline
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Supplement I to Part 226—Official Staff Interpretations

5a(a)(2) Form of Disclosures

1. Clear and conspicuous standard. For purposes of §226.5a disclosures, clear and conspicuous means in a reasonably
understandable form and readily noticeable to the consumer. As to type size, disclosures in 12-point type are deemed to be readily noticeable for purposes of §226.5a. Disclosures printed in less than 12-point type do not automatically violate the standard; however, disclosures in less than 8-point type would likely be too small to satisfy the standard.
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#459322 - 11/23/05 03:43 AM Re: Compliance requirements - the "fine print"
Andy_Z Offline
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Quote:

We just created all new brochures and that is the same thing we were told...font size 8




Several of you mentioned this. Freak referenced the only type size requirement I know of. And I was discussing in another thread one bank's privacy disclosure on the back of a statement in a 6 point font. To me, that is too small to be clear and conspicuous, but there is no standard that I know of for this. Does anyone know where 8 came from or is it just a standard SWAG?
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#459323 - 11/23/05 09:28 AM Re: Compliance requirements - the "fine print"
wavewatcher Offline
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wavewatcher
Joined: May 2003
Posts: 2,053
Hawaii
Some of the type size may be regulated by state statute. Legislature here wants to regulate the size to font 10, like local insurance disclosures.

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#459324 - 11/23/05 01:49 PM Re: Compliance requirements - the "fine print"
John Burnett Offline
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John Burnett
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Cape Cod
I can see it now: "Legislature mandates bigger type -- All disclosures must be in a point size of the greater of 8 points or the consumer's age divided by 5."

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#459325 - 11/23/05 11:26 PM Re: Compliance requirements - the "fine print"
Andy_Z Offline
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You could always hand out reading glasses, valued at less than $10, with each new account.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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