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Reg DD 1030.5: Including Advertisements

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Question: 
I have a question about Reg DD, 1030.5: can you include advertisements when sending subsequent disclosures of a new terms and conditions to the customer?
Answer: 

There is no prohibition against including marketing material with a change in terms notice provided under 1030.5. However, be sure you meet the form standard required for all disclosures under Reg DD specified in 1030.3(a) and the Official Staff Commentary to that section. The primary requirement is that disclosures be provided in a manner that the disclosures are made clearly and conspicuously. So you don't want the change buried in the middle of a bunch of marketing material where they might not be considered "clear and conspicuous".

First published on 10/30/2016

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