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#653701 - 12/18/06 06:41 PM Lobby Posters and Tents
Skyline Offline
Platinum Poster
Joined: Sep 2005
Posts: 589
Are certain disclosures required when promoting a loan product with an APR using posters and tents? Would these be the same as catalog or web advertising?

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#653766 - 12/18/06 07:44 PM Re: Lobby Posters and Tents Skyline
Love those Regs Offline
Gold Star
Joined: Apr 2002
Posts: 293
Southern State
I would view these as in-branch ads with limited disclosure and "ask us for details" type of wording. My answer would be different if the posters are setting out like brochures where a person would possibly leave with one. Then full disclosure would be needed.
Opinions are mine and subject to change frequently

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#656683 - 12/22/06 09:40 PM Re: Lobby Posters and Tents Love those Regs
Deena Offline
Power Poster
Joined: Nov 2000
Posts: 2,701
There are no exceptions for "in-branch" loan advertising. You must follow the applicable section(s) of Reg Z in full. If the APR is advertised on an open-end loan, it's a triggering term; on a closed-end loan, it's not.
Opinions expressed are mine and not necessarily those of my employer.

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