We want to promote some closed-end loan products in an advertisement designed for mobile devices. The advertisement would include terms that trigger certain additional disclosures under Regulation Z. Can we include a link in the advertisement to another webpage that will have the required disclosures?

Yes, when an electronic advertisement includes terms that trigger additional disclosures, Regulation Z and its Official Interpretations permit the advertisement to include a link that takes consumers directly to the additional required information.

For resources related to our guidance, please see:

  • Regulation Z, 12 CFR 1026.24(e)(1) (“If a catalog or other multiple-page advertisement, or an electronic advertisement (such as an advertisement appearing on an Internet Web site), gives information in a table or schedule in sufficient detail to permit determination of the disclosures required by paragraph (d)(2) of this section, it shall be considered a single advertisement if: (i) The table or schedule is clearly and conspicuously set forth; and (ii) Any statement of the credit terms in paragraph (d)(1) of this section appearing anywhere else in the catalog or advertisement clearly refers to the page or location where the table or schedule begins.”)
  • Official Interpretations, 12 CDR 1026.24(e), Comment 4 (“If an electronic advertisement (such as an advertisement appearing on an Internet Web site) contains the table or schedule permitted under § 1026.24(e)(1), any statement of terms set forth in § 1026.24(d)(1) appearing anywhere else in the advertisement must clearly direct the consumer to the location where the table or schedule begins. For example, a term triggering additional disclosures may be accompanied by a link that directly takes the consumer to the additional information.”)