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Are we required to place Truth in Savings information on retail marketing brochures (not direct solicitations)? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Are we required to place Truth in Savings information on retail marketing brochures (not direct solicitations)?

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Truth in Savings disclosures are required in marketing brochures, even if the brochure is not a direct solicitation. Under Regulation DD, an advertisement is any “commercial message, appearing in any medium, that promotes directly or indirectly: (1) The availability or terms of, or a deposit in, a new account; and (2) For purposes of §§ 1030.8(a) and 1030.11 of this part, the terms of, or a deposit in, a new or existing account.” 12 CFR 1030.2(b). If the brochure your institution is interested in sending out is a commercial message that promotes the availability of an account, the terms of an account, or a deposit in an account, then the Truth in Savings disclosures must be included in the brochure.