Skip to content
BOL Conferences
Thread Options
#602075 - 08/21/06 02:30 PM Advertisting Activity Restrictions?
LJones Offline
100 Club
LJones
Joined: Apr 2006
Posts: 156


What is the regulatory reference for the following statement?:

"If the ad refers to an account that has activity restrictions (savings accounts and money market accounts), does the ad indicate those activity restirctions that apply?"

The statement is from Page 5 of The South Financial Group's Advertising Checklist which is listed under "Banker Tools" and Advertising - Advertising Checklist

I am suggesting a change to our Deposit Rate Sheet (which is for internal and external use) and I need a reference to back-up my argument.

Thank you in advance!

Return to Top
Marketing
#602076 - 08/21/06 07:37 PM Re: Advertisting Activity Restrictions?
RVFlyboy Offline
Power Poster
RVFlyboy
Joined: Oct 2000
Posts: 5,992
Soaring over Georgia
I was the author of that document. Primary regulatory citation is 230.8(a)(1) which states that an ad shall not be misleading or inaccurate. Secondary consideration was given to Unfair or Deceptive Acts or Practices under Section 5 of the Federal Trade Commission Act. See FDIC FIL-26-2004 for more information.

While there is not a clear-cut requirement to disclose account limitations or restrictions in an advertisement, we felt from a risk-management standpoint that it was prudent for us to include a disclaimer in the ad citing the account restrictions.
_________________________
Jim Bedsole, CRCM, CBA, CFSA, CAFP
My posts - my opinions

Return to Top
#602077 - 08/21/06 08:09 PM Re: Advertisting Activity Restrictions?
LJones Offline
100 Club
LJones
Joined: Apr 2006
Posts: 156
Thanks for the explanation!

Return to Top

Moderator:  Andy_Z, MoneyMaker