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Rate Sheets

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Question: 
We have rate sheets in our branches that list various CDs and deposit accounts that list rate and APR. Generally these are used internally for our staff to know the various rates. However we have gotten into the habit of 'displaying' these on the counters where customers could pick up and take if they wished. The layout is similar to our lobby rate board. Are these considered advertisment and require all the various disclosures?
Answer: 

Yes - (b) Advertisement

1. Covered messages. Advertisements include commercial messages in visual, oral, or print media that invite, offer, or otherwise announce generally to prospective customers the availability of consumer accounts.

First published on BankersOnline.com 10/29/07

First published on 10/29/2007

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