Disclosures Required on Electronic Signs

Answer from Jim: Advertising rules for loan are found in Reg Z section 226.16 (open-end credit) and 226.24 (closed-end credit). Both sections spell out triggering terms and required disclosures for ads that contain any of those terms, and both have additional provisions for electronic advertisements. Advertising rules for deposits are found in Reg DD section 230.8 and that section also spells out some exemptions for certain types of advertising, including outdoor signs and indoor signs. Also, FDIC regulations at 12 CFR Part 328.3 contain requirements for use of the FDIC "official advertising statement" as well as some exemptions, including for advertisements on signs or plates in the insured depository institution offices or attached to the building or buildings in which such offices are located. For covered loan transactions, the Equal Housing Lender logo and legend would be required. Finally, all disclosures your management and counsel deem appropriate for avoiding Unfair or Deceptive Acts or Practices (UDAP) issues should be included.