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Advertising
In
a radio ad, can I use a 1-800 number to provide
all the Reg. M Disclosures (fact that the offer is
for a lease, amount due at lease inception,
payment schedule and end of lease liability)?
No.
For lease disclosures, a reference to an
800 phone can be used to make a very limited
number of disclosures.
However, most disclosures required when a
triggering term is used must be disclosed in the
advertisement itself.
The
text of the ad still must include:
-
that
the transaction advertised is a lease;
-
the
total amount due before or at consummation, or
by delivery if delivery occurs after
consummation; and
-
the
number, amounts, and due dates or periods of
scheduled payments under the lease.
The 1-800
number may be used to disclose mileage
allowances/penalties, and may refer to other
disclosures. This
toll-free phone number- which only applies to
radio and TV ads - must be established no later
than the ad's air date.
It also must continue for at least 10 days
after the air date. Callers must be given all the
required disclosures early in the message.
A clear and conspicuous written copy of the
disclosures also must be given to anyone who asks
for it.
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