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Consumer Leasing Act (Regulation M)

Leasing is an alternative to buying personal property with cash or on credit. A lease is a contract between a lessor (the property owner) and a lessee (the person who leases and uses the property) for the use of personal property. The lease has stated terms and limitations, is made for a specified period of time, and requires a specified lease payment.

The Consumer Leasing Act (15 U.S.C. § 1667 et seq (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) .) (CLA) was passed in 1976 so consumers get meaningful and accurate disclosure of lease terms before they enter into a contract. With this information, consumers can more easily compare one lease with another, and compare the cost of leasing with the cost of buying on credit or the opportunity cost of paying cash. In addition, the CLA limits balloon payments due at the end of the lease, and regulates advertising for leasing transactions.

The CLA was Part E of the Truth in Lending Act, originally implemented by Regulation Z. When Regulation Z was revised in 1981, Regulation M was issued, governing consumer leases.

On November 9, 2007, amendments to Regulation M and the official staff commentary were issued to simplify the regulation and provide guidance on the electronic delivery of disclosures consistent with the Electronic Signatures in Global and National Commerce Act (E-Sign Act), 15 U.S.C. §§ 7001 et seq (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) .

The Dodd-Frank Act gave the Consumer Financial Protection Bureau (CFPB) authority to make rules under the CLA. For entities under its jurisdiction, the CFPB also enforces compliance with the CLA and its implementing regulation. The CFPB restated the implementing regulation at 12 CFR Part 1013 (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) in December 2011 (76 Fed. Reg. 78500).

NOTE: NCUA Rules and Regulations § 714 (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) provides additional standards and requirements a federal credit union must follow when engaged in the leasing of personal property.

You can find the full text of the CLA here (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) .

You can find the full text of Regulation M here (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) .

You can find the full text of § 714 of NCUA Rules and Regulations here (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) .


Associated Risks

Compliance risk can occur when the credit union fails to implement the necessary controls to comply with the CLA and Regulation M.

Reputation risk can occur when the credit union incurs decreased member confidence as a result of failures resulting from leases, or incurs fines and penalties.

Strategic risk occurs when the board of directors fails to perform necessary due diligence in reviewing existing and prospective products and services for compliance.

Examination Objectives

  • To assess the quality of the credit union’s compliance management system for the CLA.
  • To determine whether lessees of personal property are given meaningful and accurate disclosures of lease terms.
  • To determine if the limits of liability are clearly indicated to lessees and correctly enforced by the credit union.
  • To ensure that the credit union provides accurate disclosures in all consumer lease advertising.

Examination Procedures

General Disclosure Requirements

  1. Review the credit union’s procedures for providing disclosures to ensure that there are adequate compliance controls and procedures.
  2. Review the disclosures provided by the credit union.
    1. Are the disclosures clear and conspicuous and provided in writing in a form the consumer may keep? For disclosures provided electronically (other than in advertising), are they provided in compliance with the consumer consent and other applicable provisions of the E-Sign Act? For advertisements accessed in electronic form, are the disclosures required by § 1013.7 (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) provided in electronic form in the advertisement? (§ 1013.3(a) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
    2. Are disclosures dated and in the prescribed format? (§ 1013.3(a)(1) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
    3. Is the information required by § 1013.4(b) through (f), (g)(2), (h)(3), (i)(1), (j), and (m)(1) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) segregated, and in a form substantially similar to the model in Appendix A (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) ? (§ 1013.3(a)(2) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
    4. Are the disclosures timely? (§ 1013.3(a)(3) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
    5. If there is more than one lessee, are the disclosures provided to any lessee who is primarily liable? (§ 1013.3(c) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
    6. If additional information is provided, is it provided in a manner that does not mislead or confuse the lessee? (§ 1013.3(b) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
    7. Are all estimates clearly identified and reasonable? (§ 1013.3(d) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
    8. Are the disclosures accurate and do they contain the information required by § 1013.4(a) through (t) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) ?
    9. Are disclosures given to lessees when they "renegotiate" or "extend" consumer leases? (§ 1013.5 (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )

Lessee Liability

  1. Review the lease estimates and calculations to ensure that there is no unreasonable balloon payment expected in the following circumstances:
    1. At early termination:
      1. Does the lessor disclose the conditions under which the lease may be terminated early, and the amount and method of determining any early termination charges? (§ 1013.4(g)(1) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
      2. Are any early termination charges reasonable? (§ 1013.4(g)(1), (q) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
    2. At lease end:
      1. If the lessor sets standards for wear and use of a leased vehicle, are the amounts or method of determining any charge for excess mileage disclosed? (§ 1013.4(h)(3) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
      2. Are standards for wear and use reasonable? (§ 1013.4(h)(2) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
    3. At lease end (for open-end leases):
      1. Does the lessor disclose limitations on the lessee’s liabilities at the end of the lease term? (§ 1013.4(m)(2) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
      2. Are the lessee and lessor permitted to make a mutually agreeable final adjustment regarding excess liability? (§ 1013.4(m)(3) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
    4. In default or late payment:
      1. Does the lessor disclose penalties or other charges for default or late payments? (§ 1013.4(q) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
      2. Are the penalties or charges reasonable? (§ 1013.4(q) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )

Advertising

  1. Review the credit union’s advertising policies and procedures to ensure adequate compliance controls and procedures.
  2. Review a sample of the credit union’s consumer leasing advertisements.
    1. Do the advertisements advertise terms that are usually and customarily available? (§ 1013.7(a) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
    2. Are the disclosures in the advertisements clear and conspicuous? (§ 1013.7(b) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
    3. Do catalogs, multiple page advertisements and electronic advertisements comply with the page reference requirements? (§ 1013.7(c) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
    4. When triggering terms are used, do the advertisements contain the required additional information? (§ 1013.7(d) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
    5. Do merchandise tags that use triggering terms refer to a sign or display that contains the required additional disclosures? (§ 1013.7(e) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )
    6. If television or radio advertisements use triggering terms but do not contain the additional terms required by § 1013.7(d)(2) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) , do they use alternative disclosure methods (i.e., direct consumers to a toll-free number or written advertisement)? (§ 1013.7(f) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )

Miscellaneous

  1. Are records and other evidence of compliance (other than for advertising requirements under § 1013.7 (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) ) retained for not less than two (2) years? (§ 1013.8 (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) )

 


Consumer Leasing Act (CLA)
(Regulation M)
Checklist

Item Description YES NO N/A
1 Does the credit union engage in consumer leasing or purchase consumer leases from lessors? (§ 1013.2(h)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)

NOTE: If not, do no further work on Consumer Leasing. Otherwise, complete the checklist, answering Yes, No, or N/A for each item.
     
2 Are disclosures made prior to consummation of consumer leases, i.e., when a binding order is made or the lease is signed? (§ 1013.3(a)(3)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
3 Are disclosures clear and conspicuous, and provided in writing in a form the consumer may keep? (§ 1013.3(a)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
4 Are electronic disclosures provided in compliance with the consumer consent and other applicable provisions of the E-Sign Act? (§ 1013.3(a)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
5 For an advertisement accessed by the consumer in electronic form, are the disclosures required by § 1013.7 (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) provided to the consumer in electronic form in the advertisement? (§ 1013.3(a)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
6 Are the disclosures given in a dated statement and made either in (i) a separate statement that identifies the consumer lease transaction, (ii) the contract, or (iii) another document evidencing the lease? (§ 1013.3(a)(1)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
7 Is information required by § 1013.4(b) through (f), (g)(2), (h)(3), (i)(1), (j), and (m)(1) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) segregated, and in a form substantially similar to the model in Appendix A (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) ? (§ 1013.3(a)(2)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
8 If the lease involves more than one lessee, are disclosures provided to any lessee who is primarily liable? (§ 1013.3(c)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
9 If additional information is provided, is it provided in a manner such that it does not mislead or confuse the lessee? (§ 1013.3(b)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
10 Are disclosures provided to at least one lessee where there are multiple lessees, and by at least one lessor when there are multiple lessors? (§ 1013.3(c)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
11 Are all estimates clearly identified and reasonable? (§ 1013.3(d)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12 Are the following disclosures made in the lease?      
12A Description of property; (§ 1013.4(a)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12B Amount due at lease signing or delivery; (§ 1013.4(b)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12C Payment schedule and total amount of periodic payments; (§ 1013.4(c)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12D Other charges; (§ 1013.4(d)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12E Total of payments; (§ 1013.4(e)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12F Regarding payment calculations:      
12Fi Gross capitalized cost; (§ 1013.4(f)(1)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Fii Capitalized cost reduction; (§ 1013.4(f)(2)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Fiii Adjusted capitalized cost; (§1013.4(f)(3)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Fiv Residual value; (§ 1013.4(f)(4)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Fv Depreciation and any amortized amounts; (§ 1013.4(f)(5)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Fvi Rent charge; (§ 1013.4(f)(6)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Fvii Total of base periodic payments; (§ 1013.4(f)(7)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Fviii Lease payments; (§ 1013.4(f)(8)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Fix Base periodic payment; (§ 1013.4(f)(9)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Fx Itemization of other charges; (§ 1013.4(f)(10)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Fxi Total periodic payment. (§ 1013.4(f)(11)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12G Regarding early termination:      
12Gi Conditions under which the lessee or lessor may terminate the lease before the end of the lease term; (§ 1013.4(g)(1)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Gii The amount or description of the method for determining the amount of any penalty or other charges for early termination; (§ 1013.4(g)(1)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Giii In a form substantially similar to the sample; (§ 1013.4(g)(2)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12H Regarding notice of wear and use:      
12Hi Whether the lessor or the lessee is responsible for maintaining or servicing the leased property, with a description of the responsibility; (§ 1013.4(h)(i)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Hii The lessor’s standards for wear and use, which must be reasonable; (§ 1013.4(h)(2)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Hiii In a form substantially similar to the sample. (§ 1013.4(h)(3)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12I Purchase option; (§ 1013.4(i)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12J Statement referencing other non-segregated disclosures; (§ 1013.4(j)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12K Liability between residual and realized values; (§ 1013.4(k)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12L Right of appraisal; (§ 1013.4(l)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12M M. For open-end leases:      
12Mi The rent and other charges paid by lessee; (§ 1013.4(m)(1)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Mii Liability at end of lease term based on residual value and any excess liability; (§§ 1013.4(m) and (m)(2)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Miii Mutually agreeable final adjustment. (§ 1013.4(m)(3)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12N Fees and taxes; (§ 1013.4(n)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12O Regarding insurance:      
12Oi Disclosure of the types and amounts of insurance that the lessee is required to have; (§ 1013.4(o)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Oii If the lessor provides insurance, are the types, amounts, and costs disclosed? (§ 1013.4(o)(1)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12P Warranties or guarantees; (§ 1013.4 (p)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Q Penalties and other charges for late payments, delinquency, or default; (§ 1013.4(q)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12R Security interest other than a security deposit; (§ 1013.4(r)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12S Regarding any information on rates:      
12Si Does the lessor use the term "annual percentage rate," "annual lease rate," or any equivalent term in the lease disclosure? (§ 1013.4(s)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
12Sii If so, does the statement "this percentage may not measure the overall cost of financing this lease" accompany the rate? (§ 1013.4(s)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
13 Are disclosures given to lessees when they "renegotiate" or "extend" their leases? (§ 1013.5) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
14 Does the credit union advertise its leasing program?

NOTE: If not, skip to end. If so, answer the questions below.
     
14A Do the advertisements include terms that are usually and customarily available? (§ 1013.7(a)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
14B Are the advertisements clear and conspicuous? (§ 1013.7(b)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
14Bi Are any affirmative or negative references to a charge that is part of the disclosure required under paragraph (d)(2)(ii) less prominent than the disclosure (except for the statement of a periodic payment? (§ 1013.7(b)(1)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
14Bii Are advertised lease rates less prominent than any disclosure required by § 1013.4 (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) (except the notice of the limitations on rate)? (§ 1013.7(b)(2)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
14C Do catalogs, multiple page advertisements and electronic advertisements comply with the page reference requirements? (§ 1013.7(c)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
14D If any triggering terms are used, are all the following disclosures made? (§ 1013.7(d)(2)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
14Di That the transaction advertised is a lease;      
14Dii The total amount due prior to or at consummation or by delivery, if delivery occurs after consummation;      
14Diii The number, amounts, and due dates or periods of scheduled payments under the lease;      
14Div Whether or not a security deposit is required;      
14Dv A statement that an extra charge may be imposed at the end of the lease term where the lessee’s liability is based on the difference between the residual value of the leased property and its realized value at the end of the lease term.      
15 Do merchandise tags that use triggering terms refer to a sign or display containing the additional required disclosures? (§ 1013.7(e)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
16 Do television or radio advertisements that do not contain the additional information required by § 1013.4(d) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) direct consumers to a toll-free number or written advertisement for additional information when triggering terms are used? (§ 1013.7(f)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
16A Is the toll-free number listed along with a reference that the number may be used by the consumer to obtain the information? (§ 1013.7(f)(1)(i)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
16B Does the written advertisement in general circulation in the community served by the radio or TV station include the name and date of the publication, and is it published beginning at least three days before and ending at least 10 days after broadcast? (§ 1013.7(f)(1)(ii)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
16C Was the toll-free telephone number available for at least 10 days, beginning on the date of broadcast? (§ 1013.7(f)(2)(i)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
16D Does the lessor provide the information required by paragraph (d)(2) via the toll-free number orally, or in writing upon request? (§ 1013.7(f)(2)(ii)) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      
17 Are records and other evidence of compliance retained for at least two (2) years as required by the CLA? (§ 1013.8) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).)      

Footnotes

Last modified on