When advertising consumer leases, it's important for marketers to make sure that their advertising complies with the Consumer Leasing Act as well as Reg M.
The rules apply whenever you're leasing personal property to an individual for more than four months for that person's personal use, so long as the total financial obligation under the lease is not more than $55,800. Although people often think of leasing in the car industry, these rules actually apply to others who advertise consumer leases too.
The FTC just published a post reminding businesses that these rules apply to leases of pets! Recognizing that pet leasing is a relatively new industry, the FTC expressed the concern that "most people considering buying a pet are not expecting to be handed a lease and many pet sellers may not be prepared to explain a lease terms."
Federal leasing rules require, among other things, that if your advertising includes certain trigger terms, then certain additional terms (such as that the transaction advertised is a lease, the total amount due at signing, the number, amounts, and due dates of payments, and whether a security deposit is required) must be disclosed in a clear and conspicuous manner.
Certainly if you're offering pet leases, this alert is important news for you. But it's also not the first time we're hearing from the FTC lately about pet products. If you're selling pet products, it's a good time to take another look at your marketing practices to make sure that they're in compliance.
It's also a good reminder for business in all industries. If you're offering leases, you'd better make sure that you comply with the rules. The FTC's guide, Advertising Consumer Leases, is a great resource for businesses that want to learn more.
If the customer misses a monthly payment, the leasing company can repossess Fluffy, Fido, or Cookie the Cockatoo