To ensure compliance with these federal legal requirements, pertinent lease or retail data must closely accompany the advertised payment or APR rate in a manner as conspicuous as the advertised payment or APR rate. A dealer must always check with their legal counsel to ensure all state and/or local regulations are also followed. ƒ To comply with “as conspicuous as” in digital banner and paid search marketing initiatives, dealers may include an MBUSA monthly offer as outlined in the current “Monthly Sales Program Guide” in their SEM copy and in doing so, must assure the landing page provides the full disclaimer for lease structure and/or APR rates. The headline/body copy may describe the vehicle and the lease or retail in general terms. It may not identify the terms required to be disclosed by the federal law in print any larger than that of all of the material terms in the disclosure box. Photography or illustrations of specific vehicles must be reflective of the advertised terms or otherwise noted. The duration of the limited time lease or sale offer must be specified. Additional State Requirements: A lease and/or APR advertisement that meets federal disclosure requirements may still fail to meet applicable state laws regarding deception and confusing advertising. Please be sure to check your state law requirements with your counsel before running any lease or APR advertising. C. Regulations Regarding Advertising Lease Offers: Federal Law, Regulation M, 12 Code of Federal Regulations, Part 213, must be complied with in full. It makes mandatory certain disclosures for any lease advertisement that contains any of the following “triggering terms”: the amount of any payment, a statement of any capitalized cost reduction, other required payment, or that no payment is required at delivery or lease consummation. If any of these triggering terms are used, the advertisement must disclose the following additional information: ƒ The transaction advertised is a lease. ƒ The total amount due prior to or at consummation/delivery. ƒ The number, amounts, and due dates or periods of scheduled payments under the lease. ƒ A statement of whether or not a security deposit is required. ƒ If applicable, a statement that the payment amount or amount due at lease signing excludes taxes, licenses, title and registration fees. 2. A disclosure of pertinent lease terms must be as readily noticeable as the advertised payment. This prominent disclosure must include the following in proximity to the advertised payment: length of term of the payment, capitalized cost reduction, acquisition fee, total cash due at signing as per the illustration that follows: “Disclosure box” example Lease rates should not be quoted in advertising. Published August 2015, Rev. 10 Mercedes-Benz Brand Communication Standards l Page 10
