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Disclosure requirements will vary based on whether the credit is open-end or closed-end. Another aspect of Regulation Z is that if an advertisement for credit states specific credit terms, “it must state only those terms that actually are or will be arranged or offered by the creditor.” In other words, advertising relating to credit must present what Regulation Z deems to be “clear and conspicuous” information.
As employees may be viewed by the public as a reflection of their company, financial institutions may be at compliance risk by what their employees say on social media when they’re off the clock.
For example, if an employee is communicating via social media with a customer regarding a loan product, policies should be in place to ensure they are receiving all of the appropriate disclosures.
Employers should evaluate the risks of social media to determine proper policies to adopt. Websites that accept loan applications online may be considered a lobby for Fair Housing Compliance purposes and should also contain the logo.