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Website Banner Advertisement

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As the Compliance Analyst for our bank, I have been asked to review a banner advertisement that will be listed on our bank website. The ad lists some of the required items under Reg DD including APY, penalty for early withdrawal, etc. The one thing it doesn’t state is the minimum balance required to obtain the APY or the minimum deposit required to open the account. The marketing department says that the work around is that when you click on the ad it takes you to a page that discloses all of the minimum balance requirements, etc. Is it OK under Reg DD that not all six requirements are together on one page and by clicking on the ad it reveals the rest of the requirements?

Comment 9 to section 230.8(a) reads as follows:

"Electronic advertising. If an advertisement using electronic communication displays a triggering term (such as a bonus or annual percentage yield) the advertisement must clearly refer the consumer to the location where the additional required information begins. For example, an advertisement that includes a bonus or annual percentage yield may be accompanied by a link that directly takes the consumer to the additional information."

Make sure that the banner ad makes it clear that the reader should click to get additional information. All of the additional required information should be on the linked page (more than one click should not be required to get all the required information). Beyond that, you should make sure that items that the regulation requires are equally conspicuous are on the same page and that they are equally emphasized. Finally, there are some items that are required to be displayed together, for example the information on a given tier for a tiered account. Make sure they are all on the same page, in this case, probably the linked page (not the banner).

First published on 1/2/07

First published on 01/02/2007

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