Abbreviated Ad Disclosures

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Question:

When can we get away with saying “Some restrictions apply. See bank for details” on an advertisement for a contest or a product? In what form do the in-bank details need to be?

Answer:

You can’t use that phrase as a replacement for terms that must be included in the advertisement. Check with counsel if the ad is for a sweepstakes or contest, to avoid the possibility of running afoul of the FTC’s (and state) rules on unfair and deceptive acts and practices. We also recommend using your checklist with marketing to ensure that Reg DD and Z triggered terms are followed.

First published on BankersOnline.com 8/24/09