I think this is stump the compliance officer day...

If we have a home loan ad for a 30 year fixed rate mortgage with an APR of 3.95 going up on an electronic billboard, it needs to have the additional terms listed in 1026.24(d)(2), right? Or...could we get by with the rationale that a 30 second electronic billboard advertising is along the lines of the television and radio alternative in .24(g)? The latter is probably a stretch but wanted to throw it out there.

You'll have a tough time convincing an examiner that a billboard is actually a broadcast receiver. A better choice would be to drop the "30 year" trigger term and just go with the APR.

I agree with Dan. An electronic billboard is not a TV/Radio ad. It's a billboard requiring full disclosures.

I didn't think the electronic billboard being a big TV along side the road was going to work.