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Advertisement for Bonus Reg DD

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This is about an advertisement that offers a bonus to a customer and one of the conditions to be met in order to qualify for the bonus is having a set number of debit transactions posted to the customer's account within a specific period of time. When disclosing this qualification in the ad for the customer, should it be specified as "posted and cleared to your account" to be more clear and conspicuous or is the language "posted to your account" sufficient? Does Reg DD indicate the need to specify the term "cleared or completed" when referring to posted?

This is a potential UDAAP issue as far as deceptive advertising. There is no guidance in the regulation regarding required language. It is going to be a business decision.

First published on 10/06/2019

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