Banner Ad Trigger Term Placement

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Question:

The new advertising rules under Reg Z require disclosures to be in "close proximity" to triggering terms. How can this be done in a website banner ad?

Answer:

The new rules basically require that trigger terms and related disclosures be immediately above, below or next to each other. There are exceptions for radio, television and electronic ads. For a web page advertisement, a trigger term in an advertisement on an internet website may be accompanied by a link that directly takes the consumer to the additional information. See comment 16(c)(1)-2 here.

First published on BankersOnline.com 3/30/09