Auto loan campaign · highway creative
MR-2026-041Awaiting you
§1 Regulation Z advertising · no triggering terms
Get On the Highway to Higher Savings. With Our Auto Loans. Credit and collateral subject to approval.
The creative states no rate, no payment amount, no number of payments or repayment period, and no downpayment, so none of the triggering terms in 12 CFR 1026.24(d)(1) is present and no additional disclosures under 1026.24(d)(2) are required. If Marketing adds a rate, it must be stated as an annual percentage rate using that term, and a rate that may increase after consummation must say so.
12 CFR 1026.24(a), (c), (d) · Regulation Z advertising requirements for consumer credit
§2 Official advertising statement · NCUA part 740
[Credit union] is insured by NCUA.
The advertising statement is present. Part 740.5 requires the official advertising statement in advertisements by a federally insured credit union, no smaller than the smallest font used elsewhere in the advertisement. Two checks before approval: confirm the wording is the official statement or a permitted short form, and confirm the font size against the disclaimer line on the final export.
12 CFR 740.5 · NCUA accuracy of advertising and notice of insured status
§3 UDAAP · the savings claim
Higher Savings
A claim is judged by its overall net impression. To a reasonable consumer, higher savings on an auto loan implies a lower cost than an alternative. If Marketing can substantiate that, keep it. If the basis is a rate comparison, stating the rate brings item 1 back into play. If it cannot be substantiated, recommend a claim that does not imply a comparison.
CFPB UDAAP Examination Procedures, deception standard · net impression · UDAAP under Dodd-Frank Act sections 1031 and 1036