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#1903346 - 03/07/14 05:15 PM CD Ad in Newspaper
Norman Paperman Offline
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Norman Paperman
Joined: Aug 2012
Posts: 1,700
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Hi Kids,

I'm in debate with my marketing department. They want to include a CD ad in the local paper.

Example:
6 month CD .50% APY
*APY (Annual Percentage Yield) is accurate as of March 1, 2014. Limited time offer. Some restrictions may apply.

Here is my issue, they believe that adding "some restrictions apply" covers the requirements listed below.

http://www.bankersonline.com/regs/12-1030/12-1030-008.html


Minimum Balance
Minimum Opening Deposit
Early Withdrawal Penalties

Your thoughts and input please.
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#1903353 - 03/07/14 05:20 PM Re: CD Ad in Newspaper Norman Paperman
manimal Offline
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manimal
Joined: Feb 2008
Posts: 2,207
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We always include the minimum opening deposit/minimum to earn interest. We also say "Penalties may apply for early withdrawal."

Hope this helps. smile
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#1903357 - 03/07/14 05:26 PM Re: CD Ad in Newspaper Norman Paperman
Norman Paperman Offline
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Norman Paperman
Joined: Aug 2012
Posts: 1,700
48.934476, -114.343735
Any idea if industry practice allows "some restrictions may apply"?

It just looks flat wrong to me. Wish I had a newspaper to view others.
_________________________
Maybe you just wanna fly the plane yourself. Well good luck pressing take off, then auto pilot, then land.


CRCM

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#1903365 - 03/07/14 05:35 PM Re: CD Ad in Newspaper Norman Paperman
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
1030.8(c) When additional disclosures are required. Except as provided in paragraph (e) of this section, if the annual percentage yield is stated in an advertisement, the advertisement shall state the following information, to the extent applicable, clearly and conspicuously:

And exactly what portion of this instruction is the marketing department unable to comprehend??? smile

Last I checked, some restrictions apply is neither.
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#1903369 - 03/07/14 05:40 PM Re: CD Ad in Newspaper Norman Paperman
Norman Paperman Offline
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Norman Paperman
Joined: Aug 2012
Posts: 1,700
48.934476, -114.343735
I learn something new every single day in this job. You have reiterated my thoughts, but in researching I figured out that a rate sheet in a newspaper, unless paid for by the FI, is not considered an advertisement.



In this case however, we are paying for the ad.

Thanks again.
_________________________
Maybe you just wanna fly the plane yourself. Well good luck pressing take off, then auto pilot, then land.


CRCM

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#1903370 - 03/07/14 05:40 PM Re: CD Ad in Newspaper Norman Paperman
manimal Offline
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manimal
Joined: Feb 2008
Posts: 2,207
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Rlcarey is dead on, the "clearly and conspicuously" part of the reg leaves little room for ambiguity.
_________________________
We're all here 'cause we've lost control.

Innerpartysystem

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#1903459 - 03/07/14 07:11 PM Re: CD Ad in Newspaper Norman Paperman
Norman Paperman Offline
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Norman Paperman
Joined: Aug 2012
Posts: 1,700
48.934476, -114.343735
Thanks all.
_________________________
Maybe you just wanna fly the plane yourself. Well good luck pressing take off, then auto pilot, then land.


CRCM

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