Big Print. Little Print. What's the Deal?

Computer sellers - online and brick-and-mortar - inundate consumers with advertisements for "free" or low-cost computers. The offers usually involve rebates of several hundred dollars off the computer's purchase price - if the consumer commits to a long-term contract for Internet service. Some of the offers may be good deals for consumers, but they are likely to involve complicated transactions.

Rebated Computers and Internet Service

Many rebate promotions use big print to tout the after-rebate price of the computer. But often, the total price the consumer must pay up-front is buried in the fine print, if it's included at all. Your advertisements should prominently state the before-rebate cost of the computer, as well as the amounts of the rebates. Only then will consumers know their actual out-of-pocket cost and have the information they need to comparison shop.

Rebate promotions should clearly detail any additional terms and conditions that consumers need to know, like:

• Penalties or fees for canceling the Internet service contract early. Some rebate offers require consumers to pay back all or a portion of the rebate; others tack on an additional fee.
• Additional connection charges to access the Internet service. For example, consumers should be told that to access the Internet they may have to pay long distance phone charges, or expensive hourly surcharges for use of an 800, 888 or 877 phone number. This charge is in addition to the basic monthly Internet service fee. Consumers also should be told how to find out if local Internet access is available.
• How long before they will receive the rebate.

Advertisers should tell consumers what components are included in the offer. For example, if a monitor is pictured in the ad but is not part of the deal, you must state this fact clearly and prominently. You also should include the cost of the monitor if it's sold as an add-on.

Don't Bury the Details

Print advertisers should not attempt to hide the real cost or the critical terms or conditions by:

• Putting them in obscure locations, such as the border area on a print ad;
• Burying them in numerous, densely packed lines of fine print; or
• Including them in small-type footnotes.

Television advertisers should not hide key information in:

• A fast moving "crawl";
• Superscripts or subscripts using small print sizes or a color that fades into the background;
• Type that disappears from the screen too fast for consumers to read and comprehend; or
• The middle of a long statement that scrolls vertically on the screen within a short period of time.

Disclosures in Internet Advertising

When using a hyperlinked disclosure, advertisers should clearly label the hyperlink so it shows the importance, nature and relevance of the information to which it links (for example, "Early cancellation of Internet Service may result in substantial penalties. Click Here."). The hyperlink should be prominent, near the claim it is qualifying, easily noticeable, and lead directly to the qualifying information. Vague labels like "Terms and Conditions" are not enough to direct consumers to important restrictions or qualifications.

For More Information

• Truth in Lending Act (TILA) of 1968. Wikipedia notes that "The Truth in Lending Act (TILA) of 1968 is a United States federal law designed to protect consumers in credit transactions by requiring clear disclosure of key terms of the lending arrangement and all costs."
• FTC Rules that Govern Telemarketing. Includes a discussion of the disclosures that must be made before a customer pays for the goods or services under the Telemarketing Sales Rule.
• Article - Disclosures Required by FTC Rules. Article discusses disclosures required by FTC rules.

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