Magazine article ABA Bank Marketing

One Click Away: These Days, It's Become Common to Advertise on Electronic Media. We've All Advertised on Our Own Web Sites for Years Now, and Targeted E-Mail Ads Are Commonplace. Now We're Trying to Get Our Arms around What Opportunities and Risks Are Involved with Advertising on Social Media Such as Facebook and Twitter

Magazine article ABA Bank Marketing

One Click Away: These Days, It's Become Common to Advertise on Electronic Media. We've All Advertised on Our Own Web Sites for Years Now, and Targeted E-Mail Ads Are Commonplace. Now We're Trying to Get Our Arms around What Opportunities and Risks Are Involved with Advertising on Social Media Such as Facebook and Twitter

Article excerpt

One hurdle becomes apparent right away: Space is at a premium, especially on Twitter, where posts are limited to no more than 140 characters. If you're running a consumer deposit ad that mentions an APY or a loan ad that mentions the repayment term, you've triggered additional disclosures. On the deposit side, just the mention of "APY" means the words "annual percentage yield" must be included, and that's 23 characters right there. How can you fit all that additional information into a tweet or other social media post? You just don't have room and even if you do, you don't want to clutter up the ad. Isn't there an easier way?

Special provisions for electronic communication

As a matter of fact, yes. Both Reg. DD (Truth in Savings, for deposit ads) and Reg. Z (Truth in Lending, for loan ads) contain provisions allowing for required disclosures in electronic communications (Web pages, e-mails, social media and so forth) to be provided in "a link that directly takes the consumer to the additional information." [Comment 9 to 12 CFR 230.8(a) and comment 4 to 12 CFR 226.24(d)] The key word in that exception, however, is "directly."

The phrase "directly takes the consumer to the additional information" essentially means one click away. The consumer shouldn't have to do anything else or search further to find the required information. When I click the link, I go right to a location that contains the disclosures. I may have to scroll down the landing page to get there, but that's OK; after all, you don't know the size of the screen the viewer is using (I may be reading a Blackberry, for instance). …

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