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Disclaimers on e-Ads & Blogs

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Question: 
I know blogs are popular for banks to use on their websites for connecting with customers and attracting new customers. While these do not fall into the traditional definitions of advertisements for disclosure purposes, do you see other banks including some type of disclaimer statement when a blog includes info such as steps to buying a home. For example, sharing info about credit score ranges, standard DTI ratios, money needed for down payment, etc. I was thinking some type of disclaimer with the blog would be appropriate, such as: "Information regarding credit scores, debt ratios and other underwriting related information are examples only and do not represent the bank's exact underwriting criteria. All applications are subject to credit approval". Is there a best practice with blogs for referencing products and services in a generic manner?
Answer: 

I’m not sure what other banks are doing but recommend not following any other bank's lead on this; make your own risk- and customer service-based decision.

If your bank indicates underwriting criteria, I would either indicate this is what your bank uses and be specific, or that these are general guidelines and each bank sets it own specific parameters. That’s a great time to say “contact us for information on loans, deposits…”

If you are not specific, some potential customers will read these as your actual criteria and argue when they don’t qualify and claim it was deceptive and misleading. That can only lead down the wrong path and that is why so many lenders use “With approved credit” in ads. Your disclaimer sounds appropriate.

First published on 02/20/2022

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