Marketing and Advertising
Advertising is regulated by product, not by channel
Every advertising rule begins with classification: deposit, closed-end credit, open-end credit, or mortgage. Then apply the applicable disclosure triggers.
Reg DD (deposits). If an advertisement states a rate, it must state the APY, the period the APY is offered, the minimum balance to earn it, and, for variable rates, that the rate may change. Terms such as free or no cost cannot be used if any condition or fee applies.
Reg Z (credit). Triggering terms are the down payment, the number of payments or period of repayment, the amount of any payment, and the amount of any finance charge. If one appears, the ad must also state the APR, the terms of repayment, and the down payment. A stated APR must be more conspicuous than any triggering term. Stating the APR alone triggers nothing.
Mortgage advertising (MAP Rule). Requires clear and prominent disclosures and bars misleading claims about fixed rates, government affiliation, and payment amounts.
FDIC insurance. Section 18(a)(4) of the FDI Act prohibits misrepresenting deposit insurance. Never attach FDIC coverage to a non-deposit product such as a mutual fund, annuity, crypto asset, or safe deposit box.
Fair lending and outreach. ECOA and the Fair Housing Act bar discouraging applicants on a prohibited basis; use the Equal Housing Lender statement in dwelling-related credit advertising. TCPA, CAN-SPAM, and Do Not Call rules govern delivery.
Trap
An ad reading only $199 per month is a triggering payment term, so APR, repayment terms, and down payment must also appear. A logo alone does not satisfy every FDIC identification requirement.