Internet Advertising

Posted By: ktac MITCH

Internet Advertising - 07/22/09 08:10 PM

I am in need of help from someone who has traveled this road.
We are considering placing "Banner Ads" for deposit products on the local newspapers website. I understand all the same triggering terms apply (ie APR spelled out / Terms for time acct / Min to open and earn int / etc)
My question is - can the banner ad have a section that says "Click here for details" and that takes them to the "fine print" disclosures?
OR - does all required info have to be in the banner ad?
Posted By: 'Lil Freak!

Re: Internet Advertising - 07/22/09 10:48 PM

A link to the disclosures would suffice.
Posted By: Richard Insley

Re: Internet Advertising - 07/23/09 05:30 PM

Even though you may not need to include a statement about deposit insurance, I'd try to find a spot for one on every deposit ad in any medium. After all, in these troubled economic times, that statement may be more interesting to a potential depositor than all the rest of your product/price message.
Posted By: Tryin-2-Comply

Re: Internet Advertising - 07/24/09 09:20 PM

can you tell me - why you believe adding a link would suffice to meet the requirements?
Posted By: rlcarey

Re: Internet Advertising - 07/24/09 09:34 PM

Commentary 230.8(a):

9. Electronic advertising. If an electronic advertisement (such as an advertisement appearing on an Internet Web site) displays a triggering term (such as a bonus or annual percentage yield) the advertisement must clearly refer the consumer to the location where the additional required information begins. For example, an advertisement that includes a bonus or annual percentage yield may be accompanied by a link that directly takes the consumer to the additional information.
Posted By: Tryin-2-Comply

Re: Internet Advertising - 07/24/09 09:36 PM

Thanks so much!