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.
We are wanting to do a promotion for our customers when they open an Interest Bearing Account (Now Account), where they will receive a $25 gift card bonus. I know that we have to use special disclosures regarding Reg DD, however do we have to submit a 1099 INT form for each customer?
If the HMDA rate spread exceeds the 3% threshold on a first mortgage, other than reporting it, is the lender obligated to provide any disclosures to the borrower as HOEPA requires?
I'm looking to assist my clients (sellers / builders) advertise special rate deals (2/1 buy down, seller paid). What disclosures do I need to advertise?
(1) Our marketing department wants to run a series of PowerPoint type clips/screens promoting various mortgage products. These would be run only on TV screens set up behind teller lines in various bank offices. Since these are to be used only in bank branch offices, does the FDIC logo need to be listed on the individual product screens? (2) The only verbiage on one screen mentions "100% Financing Mortgage", does this trigger REG Z advertising disclosures? Any difference with Bank name or without bank name?
(1) Our marketing department wants to run a series of PowerPoint type clips/screens promoting various mortgage products. They would be run only on TV screens set up behind teller lines in various bank offices. Since they are to be used only in bank branch offices, does the FDIC logo need to be included on the individual product screens? (2) The only verbiage on one screen mentions "100% Financing Mortgage," does this trigger Regulation Z advertising disclosures? Any difference with Bank name or without bank name?
If the term of an advertised home equity loan is buried in the fine print rather than used in the body of the ad, is it still considered a "triggering" term that would require us to add "$xx.xx per month per $1000 borrowed" to the fine print?
The Q&A below in the InfoVault caught my attention. Where would I find the exemption for use of the EHL logo for national banks?<dir>Question: I am trying to find the required disclosures to include the following message on exterior signage "100% Financing Available, Low Down Payments and No Hidden Fees." Can you help? Answer: I don't believe any of the information provided in this signage triggers further disclosures. Refer to Section 226.16 of Reg Z (for open-end credit advertising requirements) and Section 226.24 (for closed-end credit advertising requirements). If this is a home loan promotion, you do need to include the Equal Housing Lender logo <strong>(<u>unless your institution is regulated by the OCC</u>)</strong>.</dir>
Our residential department has a tagline on all emails, advertising a new delivery channel. When our email goes outside it comes with standard text about "If you have received this in error......"Can I link to our website for the paragraph on CAN-SPAM and opting out of these advertisements? Otherwise, our email communications are getting cluttered. Also.....any ideas on tracking emails to the opt out people? We have a system for our mass mailings, but are still debating how to stop the emails with taglines.
We would like to advertise on our bank's website a new CD product. With all of the disclosures required, the marketing department is having a tough time fitting all the required disclosures on the ad. Can we use a link on the ad to take them to the disclosures, or do they need to be on the ad itself?