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#586138 - 07/20/06 04:05 PM Outdoor Advertising
Marathon Junkie Offline
Member
Joined: Mar 2001
Posts: 50
We're getting a "jumbotron" advertising billboard. I don't know what the exact terminolgy is - but it's basically a giant TV screen that we can scroll ads, community events, weather, etc. We want to, of course, advertise our products including any current specials we're having. We'll have all the requisite disclosures posted, but is there a time limitation that the screen must be visible to be in compliance? Thanks!!
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Marketing
#586139 - 07/23/06 01:36 AM Re: Outdoor Advertising
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I'm not aware of any guidelines. Most of the advertising regulations require "clear and conspicuous", so you'll need to leave the disclosures up long enough so they can be read.
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#586140 - 07/24/06 02:07 PM Re: Outdoor Advertising
Marathon Junkie Offline
Member
Joined: Mar 2001
Posts: 50
Just a couple of follow up questions:
1. Since the jumbotron is not attached, it is my position that Member FDIC must be on it.
2. An Advertising question - 226.24 - is it permissible to place an ad on it stating "6.99 APR consumer loans - come inside for details"? This is only available in very limited circumstances and doesn't use a trigger term, but I want to include the other disclosures listed in 226.24(c)(2) because to get this rate there is a down payment required and a limited in the period of repayment - 36 months. Management doesn't want to include all the terms so will this work?
Thanks
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#586141 - 07/25/06 10:48 PM Re: Outdoor Advertising
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
1. Yes, you will "Member FDIC" every so often. This isn't a "we're located here" sign or your bank's name attached to the building. Also, be careful you don't promote Non-deposit investment products and scroll "Member FDIC" too.

2. This is fine since it is a closed-end loan and no triggering terms are given. If you say "36 months" on the electronic billboard, you do trigger more.
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http://www.bankerscompliance.com

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