Answer:
All of the disclosures can be "1 click away" (using a link). Refer to the Commentary to section 230.8(a)#9, which states:
"Electronic advertising. If an advertisement using electronic communication displays a triggering term (such as a bonus or Annual Percentage Yield) the advertisement must clearly refer the consumer to the location where the additional required information begins. For example, an advertisement that includes a bonus or Annual Percentage Yield may be accompanied by a link that directly takes the consumer to the additional information."
[Editor's Note: Regulation DD was recently amended (effective 12/10/2007), and the wording of the Comment David has cited is changed slightly. As you can see, there is no substantive change:
"Electronic advertising. If an electronic advertisement (such as an advertisement appearing on an Internet Web site) displays a triggering term (such as a bonus or annual percentage yield) the advertisement must clearly refer the consumer to the location where the additional required information begins. For example, an advertisement that includes a bonus or annual percentage yield may be accompanied by a link that directly takes the consumer to the additional information."]
First published on BankersOnline.com 12/03/07
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