Question & Answer

Question: I've not been able to get a straight answer on this question. Can you help? Does advertising under DD apply to ads on the Internet?

Answer: Well, we can add a couple of expert opinions, at any rate. In Regulation DD advertising guidelines, Section 230.8(e), it calls for exemptions for "?certain media?", but does not specifically name the Internet. But both experts on DD that we contacted agreed that the advertising guidelines would apply to the Internet, both to information on the bank's Web site, as well as any ads the bank may run on other sites, to the extent they relate to deposit-related products. So, a bank could not make false or misleading statements, could not use the term "free" if the account has any maintenance or activity fee associated with it, and would have to include certain specific disclosures if the ad contains TISA trigger terms.

Thanks to advisors Mary Beth Guard, Esq. and Phil Farley, Regulatory Mgr., Philadelphia Fed for their responses to this question.

Copyright © 2001 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 11, No. 2, 2/01