04/14/2008
What disclosures are required on an outside banner for a HELOC with an intro rate?
03/31/2008
We participate in several trade shows each year including home shows and business fairs. At each one we conduct a prize drawing where anyone who stops by our booth can enter to win a prize with no purchase necessary. Should we include a disclosure on the entry cards or on the sign?
03/24/2008
Does the one click rule apply for required disclosures when advertising with a banner on the website for home equity products featuring a discounted introductory rate?
03/17/2008
We plan to advertise our home equity loans and HELOCs in a radio ad that will say the APR for each of these loan products. What are the rules for disclosures on the radio? Do the same triggers apply to print ads?
03/17/2008
We have a new television ad, and we are new to this type. Does an announcer have to state that we are FDIC insured and an equal housing lender, or can we just display that information on the screen? I have looked at the regulations, but I am not sure what a "display advertisement" is.
03/17/2008
I am fairly new to the deposit compliance arena. Under the advertising section of Reg DD, there are exemptions for certain types of media (<a href="http://www.bankersonline.com/regs/230/230-8.html">230.8(e)</a>). One of these exemptions is broadcast or electronic media, such as television or radio. Would an advertisement on our bank's website be categorized as electronic media, and thus exempt from certain disclosure requirements, or would it be considered just like print media and thus be subject to all requirements of <a href="http://www.bankersonline.com/regs/230/230-8.html">230.8(c)</a>? I think that it should be treated just like print media, but I am having a difficult time finding any regulatory guidance to either confirm or refute this.
03/10/2008
Reg DD requires banks to disclose the fee or fees for payment of each overdraft when the bank advertises the payment of overdrafts. 12 CFR 230.11(b)(1)(i). How is this disclosure made when a bank has a tiered system in place? For example, if a bank charges a fee based on the number of overdrafts in a month. When the first overdraft is made, it is unclear how much the overdraft fee will be because you don't know how many overdrafts there will be in the month.
03/10/2008
On advertising MMDAs, do we need to include a disclosure regarding the monthly limitation on withdrawals?
02/18/2008
We are an insurance agency offering discounts to customers of a bank. The discounts apply to property and casualty insurance. Do we need to include "not FDIC insured" on our marketing materials? If so, what is the proper verbiage? Our marketing materials include the bank's name and logo.
02/11/2008
We are wanting to do a promotion for our customers when they open an Interest Bearing Account (Now Account), where they will receive a $25 gift card bonus. I know that we have to use special disclosures regarding Reg DD, however do we have to submit a 1099 INT form for each customer?