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Social Media Posts Without Member FDIC

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At this time our social media posts, facebook, twitter, google​ display ads etc. don’t’ have the Member FDIC due to character and layout constraints, however, they are one click away from our landing page that will​ have the advertising notice of FDIC membership. Would this be acceptable?

While disclosures are typically allowed to be one click away, I see little validity in the argument that "Member FDIC" is too difficult to present. An alternative would be "Click here for bank disclosures" and that is not very specific. What disclosures is the person supposed to look for, one or more, FDIC, credit card disclosures, ARM plans, etc.? The link should be somewhat specific as to what the person is seeking.

I would instead encourage the bank when the shortest compliant method in its advertising and the "Member FDIC" is short and is required.

First published on 01/22/2017

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