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Disclosures Required on Electronic Signs

Our bank compliance officer left last fall for another job. I am in charge of our electronic sign and need to find out where there is a clear/concise source of information that guides us in what we have to disclose on the sign for interest rates, terms, etc.

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.


Answer from Andy: In addition to Jim's advice, you'll want to pay particular attention to the advertisement of any NonDeposit Investment Products (NDIP) you offer and check the interagency guidance on that. (Search for "not, not, may" rules and incompatability with FDIC products.) You might look for a manual dedicated to advertising as that would assist you in many areas. You also have free Banker Tools available on BOL that may help you.

First published on 2/21/11

First published on 02/21/2011

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