Advertisements that mention the availability of free credit reports but are tied to for-charge services will have to provide a new level of disclosure – specifically about the availability of completely free credit reports as provided for by Federal law. Radio and TV restrictions will come a bit later.
The first round of restrictions prominently targets internet advertising. Services must offer “clear disclosure,” according to the Federal Trade Commission. “For example, Web sites offering free credit reports must have a disclosure, across the top of each page that mentions free credit reports, with links to AnnualCreditReport.com and FTC.gov. The amended Rule also requires nationwide consumer reporting agencies – Equifax, Experian, and TransUnion – to delay advertising for products or services on AnnualCreditReport.com until after consumers get their free credit reports.”
Radio and television restrictions don’t kick in until 9/1/10. Advertisements will have to include the following language: “This is not the free credit report provided for by Federal law.” In television’s case, the message must be stated in both the audio and the visual portion of the ad.
RBR-TVBR observation: Jingle writers of America – you have your lyrics, courtesy of the Federal Trade Commission. And you have about five months to attach some notes to them and weave them into a credit report advertisement. Now get to work!