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#2295797 - 04/11/24 03:56 PM Billboard ad with rate.
joeball Offline
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joeball
Joined: May 2004
Posts: 179
Bluegrass State
I received an ad to review for a billboard that says "You still have time to get this rate! 4.50% APY*" It also has the bank name, logo and Member FDIC.

I also received a mailer that says earn up to 4.50% APY. There are tiered rates applicable and the mailer also has the tiered APY's along with the minimum balance for each tier.

Am I correct that since this has tiered rates, that info has to be on the billboard advertisement also?

Thanks.
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Marketing
#2295803 - 04/11/24 04:30 PM Re: Billboard ad with rate. joeball
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 84,530
Galveston, TX
(b) Permissible rates.

1. Tiered-rate accounts. An advertisement for a tiered-rate account that states an annual percentage yield must also state the annual percentage yield for each tier, along with corresponding minimum balance requirements. Any interest rates stated must appear in conjunction with the applicable annual percentage yields for each tier.

Billboards are not exempt from the disclosures required under paragraph (b):

(e) Exemption for certain advertisements. (1) Certain media. If an advertisement is made through one of the following media, it need not contain the information in paragraphs (c)(1), (c)(2), (c)(4), (c)(5), (c)(6)(ii),(d)(4), and (d)(5) of this section:

(i) Broadcast or electronic media, such as television or radio;

(ii) Outdoor media, such as billboards; or

(iii) Telephone response machines.
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#2295915 - 04/15/24 04:33 PM Re: Billboard ad with rate. joeball
NU Rhules Offline
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NU Rhules
Joined: Mar 2011
Posts: 484
SE, Nebraska
rlcarey,

Your answer above says "Billboards are not exempt...", but in the cited exemption listing, the second one lists billboards.

I'm stupid. Can you help me understand?

Thanks.

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#2295916 - 04/15/24 04:38 PM Re: Billboard ad with rate. joeball
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 84,530
Galveston, TX
"it need not contain the information in paragraphs (c)(1), (c)(2), (c)(4), (c)(5), (c)(6)(ii),(d)(4), and (d)(5) of this section:"

But it needs to include everything under 1030.8(b), which is the rate disclosures.
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#2295917 - 04/15/24 04:44 PM Re: Billboard ad with rate. joeball
NU Rhules Offline
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NU Rhules
Joined: Mar 2011
Posts: 484
SE, Nebraska
Thanks rlcaery. Good stuff. Watch for a similarly dumb question from me on HELOC ads!

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