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Advertising Questions

Answered by: 
Andy Zavoina

Question: 
(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?
Answer: 

The advertisement is for mortgage products, not deposits. The Member FDIC isn't required at all, nor is it prohibited.

"No down payment" doesn't trigger additional disclosures (OSC 24(c)(1)1.)

The ad is in your bank, I think the viewer will know who the lender is if you customarily do these loans. But it makes no difference.

First published on BankersOnline.com 1/21/08

First published on 01/21/2008

Filed under: 
Operations
Filed under operations as: 
Disclosures
FDIC
IT

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