Posted By: Cracked Egg
Internet advertising Reg Z / Reg DD - 03/26/18 03:55 PM
I'm getting myself confused. (no surprise there)
When we do a loan ad on the internet, it is permissible to have a direct link for the disclosures.
1026.24(e) #4 in the interpretation: "For example, a term triggering additional disclosures may be accompanied by a link that directly takes the consumer to the additional information."
However, when advertising deposit rates on the internet, Reg DD does not allow the same thing. (that I can find)
It appears that internet deposit ads need all required disclosures and there are no exemptions.
1030.8(e) interpretation: "The exemption for advertisements made through broadcast or electronic media does not extend to advertisements posted on the Internet or sent by email"
We want to place a small internet ad on a televisions website (not a TV ad) talking about CD rates. Marketing wants to keep it as uncluttered as possible and have asked to use the "click here" option. But I don't think we can do that.
Can anyone tell me if an internet deposit account ad with triggering terms can have a link?
Thank you
When we do a loan ad on the internet, it is permissible to have a direct link for the disclosures.
1026.24(e) #4 in the interpretation: "For example, a term triggering additional disclosures may be accompanied by a link that directly takes the consumer to the additional information."
However, when advertising deposit rates on the internet, Reg DD does not allow the same thing. (that I can find)
It appears that internet deposit ads need all required disclosures and there are no exemptions.
1030.8(e) interpretation: "The exemption for advertisements made through broadcast or electronic media does not extend to advertisements posted on the Internet or sent by email"
We want to place a small internet ad on a televisions website (not a TV ad) talking about CD rates. Marketing wants to keep it as uncluttered as possible and have asked to use the "click here" option. But I don't think we can do that.
Can anyone tell me if an internet deposit account ad with triggering terms can have a link?
Thank you