Social media and other forms of electronic advertising are being used by financial institutions more every day. From a compliance perspective, however, it’s important to remember that advertisements made via email or text or an institution’s website or social media platform (e.g., Facebook, LinkedIn, Twitter) are generally not exempt from regulatory disclosure requirements.
Both Regulation Z (Truth in Lending) and Regulation DD (Truth in Savings) allow required disclosures to be “one click away” provided the link takes the viewer DIRECTLY to the disclosures applicable to a particular triggering term. In other words, they should not have to scroll down the page, click on additional links, or otherwise “search” for the information. Additionally, providing required disclosures via a QR code is not considered to be “one click away” as not everyone has a phone that is capable of scanning a QR code.
Keep in mind, while Regulation Z and Regulation DD allow “one click away” disclosures, not all regulations do. Each regulation has its own advertising requirements (and potential exceptions) which means it’s essential to review any advertisement from a variety of different lenses.
We covered this in the April issue of our magazine Banking on BCC. Be sure to check it out!
Published 2026/05/05
