Compliance Alliance Q&A 10/16/2018
For the Reg. DD - "indoor signs" exception in Section 1030.8(e)(2), I see that indoor signs are exempt from: permissible rates, when additional disclosures are required, bonuses, and certain media exemptions. My question is whether "when additional disclosures are required" includes, for example, an advertisement of "free checking" when listing products available on an indoor billboard/peg board if that board does not list features which are listed elsewhere in other advertisements for a given type of checking account and its associated fees?
The rule regarding when the bank can advertise an account as "free" does apply to indoor signs. Indoor signs are excluded from the requirements listed in subsections (b), (c), (d) and (e)(1) but the rule on "free" accounts is in subsection (a) and not excluded: https://www.consumerfinance.gov/policy-compliance/rulemaking/regulations/1030/8/
(i) Signs inside the premises of a depository institution (or the premises of a deposit broker) are not subject to paragraphs (b), (c), (d) or (e)(1) of this section. https://www.consumerfinance.gov/policy-compliance/rulemaking/regulations/1030/8/
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