I am pleased to be able to post our fist guest article from our customer Republic Bank. Brian Waters, their VP of Compliance, was kind enough to cover some basic concerns of compliance as they relate to advertising in general. Going forward, my intention is to cover compliance issues as they relate to Digital Signage specifically. We are going to reach out to both current customers and industry experts to help us in our efforts. If you or someone you know would like to contribute to our efforts, please send your comments to me at brian@captiveindoormedia.com. Again, thanks to Brian Waters at Republic Bank and be sure to check back soon for more on compliance issues as they relate to Digital Signage in the branch.
Advertising and Compliance. Can't we all just get along?
Anyone who has tried to advertise a checking account or loan knows about the struggle that can ensue between trying to cover all of the federal requirements without turning the advertisement into a block of fine-point text. In truth, what needs to be said is often simple! Here are a few helpful hints for some common products.
It goes without saying, that any advertisement has to be accurate and not misleading. Also, be sure to avoid the use of the word “free” if there are any charges attached to the free service.
When advertising a checking or savings account, remember you have got to comply with the Truth in Savings Act. It sounds complicated, but it actually simple. As a rule, remember that any interest rate should be stated as the Annual Percentage Yield or APY and be sure to list the minimum balance to open the account. Also, if you have a bonus offer be sure to explain what your client need to do to qualify for that incentive. Finally, don’t forget to reference any penalties that may apply.
For consumer loans, be sure to check out the requirements found in the Truth in Lending Act. It clearly spells out the “triggering terms” that will require additional disclosures. It is important that you familiarize yourself with the triggers, because if your ad does not state them, you do not need additional disclosures! However, if you do trigger disclosures, you need to be sure to include the amount of down payment, the terms of how the loan will be repaid, and the Annual Percentage Rate. Finally, for mortgage loans, be sure to include the required Equal Housing Lending logo.
Advertising rules are fairly simple. They have been around for decades and rarely change. Just take a few minutes to embrace them and you can rest easy knowing you are in compliance without sacrificing the message you wanted your advertisement to convey!
Brian Waters,
VP, Compliance & BSA Officer
Republic Bank & Trust Company
