From the Hotline

By Teri Henning, General Counsel
Pennsylvania Newspaper Association

Q: We are considering running an ad that relates to the sale of uncut sheets of “real money.” The ad includes illustrations of U.S. currency that are in color and close to the same size as real money, although they contain the word “specimen” on them. Any problems?

A: These types of ads raise a number of potential problems that should be considered before running them.
Under federal law, any color illustrations of U.S. currency must be smaller than ¾ or greater than 1 ½ the size of actual paper currency. Any such illustration must be one-sided, and all “negatives, plates, digitized storage medium, graphic files, magnetic medium, optical storage devices, and any other thing used in the making of the illustration that contain an image of the illustration or any part thereof shall be destroyed and or deleted or erased after their final use.” 31 C.F.R. 411.1.

Any such ad should also clearly and conspicuously state that the company involved is not affiliated with any government agency.

In addition, the United States Postal Regulations require editorial-style ads to include the word “Advertisement” in a prominent place on the ad. The regulations require that the word “advertisement” be prominent (in bold or italicized print or otherwise emphasized) on the first page of the material. The word “Advertisement” should be prominent, preferably in bold print, and easy to read.

Under the Pennsylvania Unfair Trade Practices and Consumer Protection Law, a publisher will not be liable for a false or misleading ad, as long as the publisher has printed the ad "in good faith" and "without knowledge" of the misleading nature of the ads. If the above standards are satisfied, we are not aware of any unlawful activity occurring as part of the sale of these bank books. It is worth noting, however, that uncut “sheets of money” can be purchased directly from the United States Bureau of Engraving and Printing: http://www.bep.treas.gov/document.cfm/18/120

Use this link to the Headlines & Deadlines archive of Teri Henning's weekly 'From the Hotline' columns. 

[HOTLINE ARCHIVE]