We have been presented with an ad request to be displayed on a billboard. We have a 12 month introductory rate of x.xx. After 12 months the rate goes to the standard rate. Ad has the introductory rate in the "flashy" part of the advertisement with an asterisk. The standard rate is found below in the disclosures part of the ad. All information is disclosed properly in the bottom part of the ad. My question is, would you all consider this to satisfy the requirement to provide the standard rate in close proximity above, below, or beside the intro rate? Much debate here on if this satisfies the requirement, or if it needs to be included in the actual ad content versus found in a disclosure section. Thank you for your input.

Is this a loan or a deposit account ad. And if a loan, what type of product.

Credit card

2. Clear and conspicuous standard—promotional rates or payments; deferred interest or similar offers. i. For purposes of §1026.16(d)(6), a clear and conspicuous disclosure means that the required information in §1026.16(d)(6)(ii)(A)-(C) is disclosed with equal prominence and in close proximity to the promotional rate or payment to which it applies.

That means right next to the non-discounted rate in the same, size and flashiness.

Thank you so much! I really appreciate the quick response.

Sorry wrong citation:

3. Prominent location closely proximate. For written or electronic advertisements, information required to be disclosed in §1026.16(g)(4)(i) and, as applicable, (g)(4)(ii) and (g)(4)(iii) that is in the same paragraph as the first listing of the promotional rate or promotional fee is deemed to be in a prominent location closely proximate to the listing. Information disclosed in a footnote will not be considered in a prominent location closely proximate to the listing.