Advertising Guidelines GUIDELINES

PAYMENT SOLUTIONS ADVERTISINGAdvertising Guidelines GUIDELINES

Understanding Offer Channel Monthly Additional the Guidelines Descriptions Examples Payment Guidance Advertising

References

© 2020 Synchrony Financial. All rights reserved. No reuse without prior written consent from Synchrony Financial. Home Understanding Offer Channel Monthly Payment Additional the Guidelines Descriptions Examples Advertising Guidance

Guide Overview Guide Overview These Advertising Guidelines provide information to help advertise promotional financing offers associated with Synchrony Bank’s credit card products. For more specific guidance not covered in these Guidelines, please contact your Synchrony Regulatory Representative. Overview

Advertising and marketing to prospective customers is one of the most important activities we do. It promotes product awareness, the availability of credit to all creditworthy customers and provides information about our products and services with a view toward urging action on the part of the recipient. In responding to the “call to action” communicated by marketing efforts, customers are relying on the clarity and truthfulness of statements made in the marketing piece. As a valued Synchrony partner, you are responsible for ensuring that advertising and offers approved by Synchrony are presented and executed in a compliant manner.

Regulatory Overview Guide Overview Fair Lending UDAAP TILA Requirements Regulatory Overview • Federal and State Unfair, • These requirements apply to • Credit must be offered to all Deceptive and Abusive Acts and everyone, not just Synchrony Bank applicants fairly and consistently. Practices Laws (UDAAP). These as the creditor. Therefore, all Failure to do so may result in laws apply to everyone, not just people and businesses must allegations of discrimination, Synchrony Bank as the creditor, comply with Regulation Z if they potential violations of federal or and require advertisements to advertise consumer credit state fair lending laws, litigation or fairly and accurately state the transactions. The following site reputational risk. terms of the offer and not be provides specific information All applicants should be false or misleading. about the Consumer Financial encouraged to apply for credit Protection Bureau (CFPB): without fear of discrimination, https://www.consumerfinance which is prohibited by law. Types • Specific credit advertising requirements are addressed in the .gov of discrimination includes race, Truth in Lending Act (TILA) color, religion, national origin, gender, marital status, age, source of income (in whole or in part) from public assistance programs, or an applicant's good faith exercise of a right under the Consumer Credit Protection Act.

Example is illustration only. Three Parts of an Offer Ask your Synchrony representative to provide specific promotion language based on Three Parts the offer selected, or access Advertising Center at www.synchronybusiness.com of an Offer

Headline Headline Sub-headline (“Subhead”) Sub-headline Disclosure

Disclosure 1. Headline First copy a consumer reads standing out from the rest of the advertisement. Types of Promotional Tying an Offer Headline to the Disclosure Financing Offers If a superscript symbol or number is used to identify that there is a disclosure associated with the headline, generally place that superscript at the end of the Ways to Advertise Promotional headline, although on occasion it may make sense to place it in a different location Financing within the headline or sub-headline.

Advertising Templates CONTINUE

Headline Headline Sub-headline (“Subhead”) Sub-headline Disclosure

Disclosure 2. Sub-headline Contains material information about the offer. Types of Promotional Location Financing Offers The Sub-headline must: 1. immediately follow, be connected, or adjacent to the Headline, Ways to Advertise Promotional 2. be presented in a reasonable size in relation to the Headline, and Financing 3. be provided in a clear and conspicuous manner.

Advertising Templates BACK CONTINUE

Headline Headline Sub-headline (“Subhead”) Sub-headline Disclosure

Disclosure 2. Sub-headline (continued) Size Types of Sub-headline must be in a reasonable size in relation to the Headline, but not less than Promotional 10pt font (based on a standard 8.5 x11 piece of paper). Increase the font size Financing Offers proportionately for larger collateral. A good benchmark is 40% of the Headline Ways to Advertise especially since the sub-headline cannot look like a disclosure. Promotional Financing

Advertising Templates BACK CONTINUE

Headline Headline Sub-headline (“Subhead”) Sub-headline Disclosure

Disclosure 3. Disclosure Provides additional important information about the offer that a consumer should know Types of before deciding to take advantage of the advertised service or product. The disclosure Promotional may not contradict or take away from the general impression of the offer. Financing Offers

Ways to Advertise Promotional Financing

Advertising Templates BACK CONTINUE

Headline Headline Sub-headline (“Subhead”) Sub-headline Disclosure

Disclosure 3. Disclosure (continued) Location of the Disclosure Depends on the Advertising Channel/Format: Types of • Single page document: Disclosure needs to be on the same page as the offer. If Promotional Financing Offers disclosure is on the reverse/back side of the page, a redirect (See reverse for details, etc.) is required on the side of the document with the offer. Ways to Advertise • Multi-page document: Disclosure can be on the same page or a different page of Promotional the document. If disclosure is not on the same page, a redirect (See page XX for Financing details) is required on the page with the offer. • Digital: Disclosure must be on the same page or no more than one click Advertising Templates away from the offer. BACK CONTINUE

Headline Headline Sub-headline (“Subhead”) Sub-headline Disclosure

Disclosure 3. Disclosure (continued) Size Types of Minimum font size for disclosure copy is 8pt (based on a standard 8.5 x 11 piece of Promotional Financing Offers paper). Increase the font proportionately for larger collateral. The disclosure must be easily readable, considering the size, format, channel and location of the Ways to Advertise advertisement. For instance, make sure print color contrasts with background color to Promotional ensure that the disclosure is legible. Financing

Advertising Templates BACK CONTINUE

Three Parts of an Offer Three Parts of an Offer 3. Disclosure (continued) Tying an Offer to the Disclosure

Headline An offer must be connected to its disclosure Example is illustration only. in a manner that allows a consumer to easily Ask your Synchrony representative to provide find and read it. How to do this: specific promotion language based on the offer selected, or access Advertising Center at Sub-headline OPTIONS www.synchronybusiness.com • Place the same superscript symbol or number in the appropriate location within the offer (typically, the headline) and at the beginning of the corresponding disclosure. Disclosure If there is more than one offer in a document, a different superscript symbol or number must be used for each one. • If multiple disclosures are required on one piece, use one superscript symbol or number Types of within each headline requiring a disclosure. Then preface the disclosure section with that Promotional same superscript symbol or number and identify each disclosure with an abbreviated Financing Offers version of the headline in bold or underlined. Present information in a logical order. Ways to Advertise • Place the disclosure immediately after the headline and sub-headline for a space Promotional constrained piece such as a billing statement overlay. When this close proximity Financing approach is used, a superscript symbol is not required. • Digital: May use “Click for details” or “See below” or other indication of where the Advertising disclosure is located, with or without superscripts, if the link is worded in a manner that Templates allows a reasonable consumer to identify the appropriate disclosure.

BACK © 2020 Synchrony Financial. All rights reserved. No reuse without prior written consent from Synchrony Financial. Home Understanding Offer Channel Monthly Payment Additional the Guidelines Descriptions Examples Advertising Guidance

Synchrony offers the following types of Promotional Financing Three Parts of an Offer DI: Deferred Interest (promo terms expire at end of promo period)

Types of Interest accrues on the promotional purchase during the promotional Promotional period at the accountholder’s standard rate for their account, Financing Offers and is shown on the billing statement as accrued interest. Ways to Advertise A minimum monthly payment is required, and varies based on the Promotional accountholder’s balance. Each billing statement will display the Financing required total monthly payment due on the account.

Advertising Templates EPNI: Equal Pay No Interest (promo terms never expire) No interest is assessed on the promotional purchase. Equal monthly payments are required until the promotion is paid in full.

FPRA: Fixed Pay Reduced APR (promo terms never expire)

Interest is assessed on the promotional purchase at a reduced APR starting from the purchase date. Fixed monthly payments are required until the promotion is paid in full.

Ways to Advertise Promotional Financing Three Parts of an Offer Synchrony’s Promotional Financing offers are typically advertised in one of three Types of ways (Trigger, Combo or Generic headlines) and the less specific the headline, Promotional the fewer disclosure requirements apply. Financing Offers Trigger Combo Generic Ways to Advertise Headlines Headlines Promotional Headlines Financing Include a trigger term No trigger terms Neither a trigger term such as “No Interest” are included, but a nor the promotional Advertising or a specific APR promotional period period are advertised. Templates such as 0% is advertised such Example: Special as 12 Months Financing Available

When deciding which type of advertisement to choose, consider the space available for your advertisement, the level of details the client is willing to provide and the entire consumer experience.

In any event, before consumers commit to make a promotional financing purchase, the full offer details must ALWAYS be available to them in the channel they can make a purchase in so they can make an informed decision whether to select the promotional CONTINUE financing for their purchase or not.

Three Parts of an Offer

Types of Trigger Headline Promotional Includes a “trigger” term as defined by Regulation Z that Financing Offers requires specific additional disclosures. Trigger terms include: • Any reference to an APR, Interest Rate or No Interest • No Annual Fee/No Foreign Transaction Fee EXAMPLES Ways to Advertise No Interest if Paid in Full Within 12 Months • Any reference to Minimum Interest Charge Level of • Promotional • 4.99% APR for 12 Months • Any other finance charges like promotion/activation fees Complexity Financing If an advertisement includes a trigger term, the following • 0% Interest for 48 Months information applicable to the program must be disclosed: and details • No Annual Fee for the first year • Current APR(s), required in Advertising • Any promotional, activation or annual fee, and the ad Templates • Minimum Interest Charge

Combo Headline EXAMPLES No trigger terms, but a promotional period or time • 12 Month Promotional Financing Available frame is included. • Ask about 48 Month Special Financing

Generic Headline EXAMPLES No trigger terms, promotional period or timeframes are • Promotional Financing Available included in the headline. • Special Financing Available

BACK

The following pages describe how to create Trigger Term ads for Three Parts of an Offer each Promotional Financing Type and Promotional Offer

Types of Promotional • Trigger Term Ads for DI (Deferred Interest) Financing Offers • Trigger Term Ads for EPNI (Equal Pay No Interest) Ways to Advertise Trigger Term Ads for FPRA (Fixed Pay Reduced APR) Promotional • Financing

Reminder: Trigger terms are terms that, when used, require you to include Advertising Templates specific additional disclosures in your offer. Regulation Z defines these.

Creating a Trigger Term Ad

Creating a Combo Promo Financing Ad

Creating a Generic Promo Financing Ad

Creating a Trigger Term Ad: Deferred Interest Headline Three Parts of an Offer Template Language Format Guidance Font size and treatment must Types of Use one of the following Main Headlines: No Interest if paid in full within [XX] Months be the same for all language Promotional • • No Interest if paid in full by [Month, Year] in the headline. Financing Offers • Zero Interest if paid in full within [XX] Months • Zero Interest if paid in full by [Month, Year] Ways to Advertise • 0 Interest if paid in full within [XX] Months Promotional • 0 Interest if paid in full by [Month, Year] Financing Note: 0% Interest CANNOT be used since interest accrues with this type of offer and is assessed if the promotional purchase balance is not paid in full within the promo period. Advertising Templates [Language in brackets is required but varies].

Creating a Trigger Term Ad

Creating a Combo Promo Financing Ad

Creating a Generic Promo Financing Ad CONTINUE

Creating a Trigger Term Ad: Deferred Interest Sub-headline Three Parts of an Offer Template Language

Based on Reg Z requirements and material terms of the promotional offer, create a Sub-headline similar to one of Types of the following options: Promotional Financing Offers Sub-headline that can be used for any channel On purchases made with your [name of credit card] . Interest will be charged to your account from the purchase date if Ways to Advertise the promotional balance is not paid in full [within XX Months] [by Month, Year]. Minimum monthly Promotional payments required. Financing Banner/Envelope Exception The “Interest will be charged…” sentence is required by Reg Z unless a banner or envelope exception exists. The Advertising other information above is deemed to be material from a UDAAP perspective and therefore even when the Reg Z Templates exception exists, the sub-headline must still indicate, as applicable, any limited time nature of the offer, the fact that not all purchases qualify and what specific credit card must be used. A detail page with all non-truncated promo headline/sub-headline/disclosure information must be provided one click away from the banner or inside the envelope. Creating a Example: Limited Time on qualifying purchases with a [name of credit card]. Trigger Term Ad

[Language in brackets is required but varies]. Creating a Combo Promo Financing Ad

Creating a Generic Promo Financing Ad BACK CONTINUE

Creating a Trigger Term Ad: Deferred Interest Disclosure Three Parts of an Offer Template Language Customize the Disclosure as applicable for how the promo works for the specific program using language similar to Types of one of the following options. Determine which option will be used to tie it to the headline. Promotional GENERAL DISCLOSURE THAT CAN BE USED FOR ANY CHANNEL Financing Offers No Ways to Advertise interest will be charged on the promo balance if you pay it off, in full, within the promo period. If you do not, interest Promotional will be charged on the promo balance from the purchase date. The required minimum monthly payments may or may not pay off the promo balance before the end of the promo period, depending on purchase amount, promo length and payment allocation. Regular account terms apply to non-promo purchases and, after promo period Advertising ends, to the promo balance. Insert New Account APR/Minimum Interest Charge]. Existing cardholders: See your credit card agreement terms. Subject to credit approval. Templates TRUNCATED DISCLOSURE FOR IN STORE SIGN when in store brochure is readily available with full disclosure Creating a Regular account terms apply to non-promo purchases and, after promo period ends, to the promo balance. Insert Trigger Term Ad New Account APR/Minimum Interest Charge]. Existing cardholders: See your credit card agreement terms. See [insert exactly where in the store the brochure is available] for important details. Subject to credit approval.

Creating a Combo TV/RADIO AD DISCLOSURE ALLOWED due to limited time and space Promo Financing Interest will be charged to your account from the purchase date if the promotional balance is not paid in full within [XX] months. [Insert New Account APR/Minimum Interest Charge]. Subject to credit approval. Ad See [insert where] for details.

Creating a Generic [Language in brackets is required but varies]. Promo Financing Ad BACK

Creating a Trigger Term Ad: EPNI Headline Three Parts of an Offer Template Language Format Guidance

Reasonable variation is allowed Types of Use one of these Preferred Headlines: in font/color/size, provided that Promotional • [No][0][0%][Zero] Interest with equal monthly payments for [X] months key terms of the offer are Financing Offers • [No][0][0%][Zero] Interest with [X] equal monthly payments presented in an understandable • 0% APR with equal monthly payments for [X] months way for consumers. Ways to Advertise • 0% APR with [X] equal monthly payments Promotional • Interest Free Financing with equal monthly payments Financing for [X] months • Interest Free Financing with [X] equal monthly payments

Advertising OR Templates Choose one of the following Other Main Headlines: • [X] Months Interest Free Financing • Interest Free Financing for [X] Months Creating a • No Interest for [X] Months Trigger Term Ad • No Interest until paid in full • [Zero] [0] [0%] Interest [for X Months] [until paid in full] See next page • 0% APR [for X Months][until paid in full] for your required Creating a Combo • Interest free financing until [Month, Year] Sub-headline options Promo Financing • No Interest until [Month, Year] Ad • [Zero] [0] [0%] Interest until [Month, Year] • 0% APR until Month, Year Creating a Generic Promo Financing [Language in brackets is required but varies]. Ad CONTINUE

Creating a Trigger Term Ad: EPNI Sub-headline Three Parts of an Offer Template Language

Based on Reg Z requirements and material terms of the promotional offer, Types of create a Sub-headline similar to one of the following options: Promotional Financing Offers Sub-headline for Preferred Headline On made with your [name of credit card] . Promotional Financing Sub-headline for Other Headline Options On made with your [name of credit card] . Equal Advertising monthly payments required for [XX] months. Templates Exception for Limited Space Situations A Truncated Sub-headline can be used in one of the following limited space situations where the details are still provided in the same channel (not applicable for TV/Radio) Creating a • Online banner – A detail page with all non-truncated promo headline/sub-headline/disclosure information must Trigger Term Ad be provided one click away without any scrolling required to see the headline/sub-headline. • Print (not applicable to in store signs unless a brochure with the full promo details is readily available in the store) – A detail page with all non-truncated promo headline/sub-headline/disclosure information must be provided in Creating a Combo the same channel. Promo Financing Ad (continued on next page)

[Language in brackets is required but varies]. Creating a Generic Promo Financing Ad BACK CONTINUE

Creating a Trigger Term Ad: EPNI Sub-headline Three Parts of an Offer Template Language Exception for Limited Space Situations (continued) Types of Since the information presented in the sub-headline is deemed material terms of the promotional offer, from a Promotional UDAAP perspective, even when use of a Truncated Sub-headline is allowed, it must still indicate to the consumer the Financing Offers following general concepts about the offer, as applicable: • Any limited time nature of the offer (either with specific dates or the phrase “Limited Time”) Ways to Advertise • The fact that not all purchases qualify for the offer, if applicable. This can be accomplished with language indicating the specific qualifying purchase or that there are product limitations to the offer. Examples: qualifying Promotional purchases, select items, qualifying merchandise, select [mattresses] Financing • That the offer requires use of a Synchrony credit card - by name or with specific card art.

Truncated Sub-headline Example – Note: Second sentence is not required if a Preferred Headline is used. Advertising Limited Time on qualifying purchases with a [name of credit card]. Templates Equal Monthly payments required for [XX] months. With all that said, the more specific information that can be included in the Truncated Sub-headline, the better.

[Language in brackets is required but varies]. Creating a Trigger Term Ad See next page for your required Creating a Combo Disclosure options Promo Financing Ad

Creating a Generic Promo Financing Ad BACK CONTINUE

Creating a Trigger Term Ad: EPNI Disclosure Three Parts of an Offer Template Language Customize the Disclosure as applicable for how the promo works for the specific program using language similar to Types of one of the following options. Determine which option will be used to tie it to the headline. Promotional GENERAL DISCLOSURE THAT CAN BE USED FOR ANY CHANNEL Financing Offers No Ways to Advertise interest will be charged , and equal monthly Promotional payments are required on promo purchase until it is paid in full. The payments equal the initial total promo purchase Financing amount divided by the number of months in the promo period, rounded up to the next whole dollar. These payments may be higher than the payments that would be required if this purchase was a non-promo purchase. Regular account terms apply to non-promo purchases. [Insert New Account APR/Minimum Interest Charge]. Existing Advertising cardholders: See your credit card agreement terms. Subject to credit approval. Templates TRUNCATED DISCLOSURE FOR IN STORE SIGN when in store brochure is readily available with full disclosure: The monthly payments equal the initial total promo purchase amount divided by the number of months in the promo Creating a period, rounded up to the next whole dollar. Regular account terms apply to non-promo purchases. [Insert New Trigger Term Ad Account APR/Minimum Interest Charge]. Existing cardholders: See your credit card agreement terms. See [insert exactly where in the store the brochure is available] for details. Subject to credit approval.

Creating a Combo TV/RADIO AD DISCLOSURE ALLOWED due to limited time and space Promo Financing Monthly payments equal the promo purchase divided by number of months in promo period rounded to next highest whole dollar. [Insert New Account APR/Minimum Interest Charge]. Subject to credit approval. Ad See [insert where] for details.

Creating a Generic [Language in brackets is required but varies]. Promo Financing Ad BACK

Creating a Trigger Term Ad: FPRA Headline Three Parts of an Offer Template Language Format Guidance Reasonable variation is allowed Types of Use one of these Preferred Headlines: [XX.XX%] APR with fixed monthly payments for [XX] months in font/color/size, provided that Promotional • • [XX.XX%] APR with [XX] fixed monthly payments key terms of the offer are Financing Offers • Reduced [XX.XX%] APR and fixed monthly payments equal to presented in an understandable [X.XX%] of promo purchase amount until paid in full. way for consumers. Ways to Advertise Promotional OR Financing Choose one of the following Other Main Headlines: • [XX.XX% ]APR for [XX] Months Advertising • [XX.XX% ]APR until [Month, Year] Templates • [XX.XX%] APR until paid in full]

Creating a [Language in brackets is required but varies]. Trigger Term Ad See next page for your required Creating a Combo Sub-headline options Promo Financing Ad

Creating a Generic Promo Financing Ad CONTINUE

Creating a Trigger Term Ad: FPRA Sub-headline Three Parts of an Offer Template Language Based on Reg Z requirements and material terms of the promotional offer, create a Sub-headline similar to one of Types of the following options: Promotional Sub-headline for Preferred Headline Financing Offers On made with your [name of credit card] . Ways to Advertise Promotional Sub-headline for Other Headline Options Financing On purchases made with your [name of credit card] . Fixed monthly payments required for [XX] months. When the promotion is good through a stated month/year (i.e. “until May 2020”) use the following as the last Advertising sentence of the sub-headline if promotion is coded to work like this: Fixed monthly payments required until Templates [Month, Year].

Exception for Limited Space Situations A Truncated Sub-headline can be used in one of the following limited space situations where the details are still Creating a provided in the same channel (not for TV/Radio) Trigger Term Ad • Online banner – A detail page with all non-truncated promo headline/sub-headline/disclosure information must be provided one click away without any scrolling required to see the headline/sub-headline. • Print (not applicable to in store signs unless a brochure with the full promo details is readily available in the store) Creating a Combo A detail page with all non-truncated promo headline/sub-headline/disclosure information must be provided in the Promo Financing same channel. Ad [Language in brackets is required but varies]. Creating a Generic Promo Financing Ad BACK CONTINUE

Creating a Trigger Term Ad: FPRA Sub-headline Three Parts of an Offer Template Language Exception for Limited Space Situations (continued) Types of Promotional Since the information presented in the sub-headline is deemed material terms of the promotional offer from a Financing Offers UDAAP perspective, even when use of a Truncated Sub-headline is allowed, it must still indicate to the consumer the following general concepts about the offer, as applicable: • Any limited time nature of the offer (either with specific dates or the phrase Limited Time). Ways to Advertise • The fact that not all purchases qualify for the offer, if applicable. This can be accomplished with language Promotional indicating the specific qualifying purchase or that there are product limitations to the offer. Examples: qualifying Financing purchases, select items, qualifying merchandise, select [mattresses]. • That the offer requires use of a Synchrony credit card - by name or with specific card art. • Truncated Sub-headline Example: Limited Time on qualifying purchases with a [name of credit card]. Advertising Fixed monthly payments required for [XX] months. Templates • The more specific information that can be included in the Truncated Sub-headline, the better.

[Language in brackets is required but varies]. Creating a Trigger Term Ad See next page for your required Creating a Combo Disclosure options Promo Financing Ad

Creating a Generic Promo Financing Ad BACK CONTINUE

Creating a Trigger Term Ad: FPRA Disclosure Three Parts of an Offer Template Language Customize the Disclosure as applicable for how the promo works for the specific program using language similar to Types of one of the following options. Determine which option will be used to tie it to the headline. Promotional Financing Offers GENERAL DISCLOSURE THAT CAN BE USED FOR ANY CHANNEL Ways to Advertise Interest will be charged on the promo purchase from the Promotional purchase date at a reduced [XX.XX%] APR, and fixed monthly payments are required until paid in full. These Financing payments are equal to X.XX% of initial total promo purchase amount, rounded up to the next whole dollar. These payments may be higher than the payments that would be required if this purchase was a non-promo purchase. Regular account terms apply to non-promo purchases. [Insert New Account APR/Minimum Interest Charge]. Advertising Existing cardholders: See your credit card agreement terms. Subject to credit approval. Templates TRUNCATED DISCLOSURE FOR IN STORE SIGN when in store brochure is readily available with full disclosure The monthly payments are equal to [X.XX%] of initial total promo purchase amount and rounded up to the next Creating a whole dollar. Regular account terms apply to non-promo purchases. [Insert New Account APR/Minimum Interest Trigger Term Ad Charge]. Existing cardholders: See your credit card agreement terms. See [insert exactly where in the store the brochure is available] for details. Subject to credit approval.

Creating a Combo TV/RADIO AD DISCLOSURE ALLOWED due to limited time and space Promo Financing Monthly payments equal [X.XXX%] of promo purchase rounded to next highest whole dollar. [Insert New Account APR/Minimum Interest Charge]. Subject to credit approval. See [insert where] for details. Ad [Language in brackets is required but varies]. Creating a Generic Promo Financing Ad BACK

Creating a Combo Promotional Financing Advertisement Three Parts of an Offer Reminder: Combo language is offer language that does not include trigger terms but advertises a Types of promotional period, such as 12 Months. This applies to all three offer types (DI, EPNI, & FPRA). Promotional Financing Offers Template Language Format Guidance Choose one of the following Main Headlines: Reasonable variation is Ways to Advertise • XX Months Financing allowed in Promotional • XX Months Financing font/color/size. Financing

If the underlying Promotional Financing offer is a Deferred Interest offer, then the word Promotional or Special Advertising must be included in the headline. Why is that? Unlike EPNI and FPRA offers, Deferred Interest promotions are not Templates structured to pay off the purchase within the specific promo period.

Based on the material terms of the promotional offer, create a Sub-headline similar to the following: Creating a Trigger On purchases made with your Term Ad [name of credit card] . Sub-headline Exceptions (Not applicable to TV, Radio) Creating a You do not need a sub-headline (or you can use any part of the sub-headline), if the credit card is not mentioned. Combo Promo (continued on next page) Financing Ad [Language in brackets is required but varies]. Creating a Generic Promo Financing Ad CONTINUE

Creating a Combo Promotional Financing Advertisement Three Parts of an Offer Template Language Sub-headline Exceptions (Not applicable to TV, Radio) – Continued Types of Limited Space Situations: If the credit card is mentioned, you can use a Truncated Sub-headline ONLY in one of Promotional the following limited space situations if the details of the offer are provided in that same channel as set forth below. Financing Offers • Online banner – A detail page with all non-truncated Combo or Trigger Terms headline/sub-headline/disclosure information must be provided one click away, without any scrolling required to see the headline/sub-headline. • Print (not applicable to in store signs unless a brochure with the full promo details is readily available in the store) Ways to Advertise A detail page with all non-truncated Combo or Trigger Terms headline/sub-headline/disclosure information must be Promotional provided in the same channel. Financing A truncated sub-headline must still indicate to the consumer the following general concepts about the offer, as applicable: Advertising • Any limited time nature of the offer (either with specific dates or the phrase Limited Time). Templates • The fact that not all purchases qualify for the offer, if applicable. This can be accomplished with language indicating the specific qualifying purchase or that there are product limitations to the offer. Examples: qualifying purchases, select items, qualifying merchandise, select [mattresses]. • That the offer is tied to use of a Synchrony credit card - by name or with specific card art. Creating a Trigger Truncated Sub-headline Example: Limited Time on qualifying purchases with a [name of credit card]. Term Ad Customize the Disclosure as applicable and determine which option will be used to tie it to the headline Subject to credit approval. Minimum monthly payments required. See [insert] for details. Creating a Use a Trigger Term headline/sub-headline/disclosure as the combo disclosure if you cannot confirm that a retailer can present the details of the offer prior to a consumer making a purchase. Combo Promo Financing Ad [Language in brackets is required but varies]. See the References for examples of pre-approved Combo Headlines Creating a Generic Promo Financing Ad BACK

Creating a Generic Promotional Financing Advertisement Three Parts of an Offer Reminder: Generic language is offer language that does not include trigger terms or a promotional period Types of or timeframe. This applies to all three offer types (DI, EPNI, & FPRA). Promotional Financing Offers Template Language Format Guidance Choose one of the following Main Headlines: Reasonable variation is Ways to Advertise • Promotional Financing Available allowed in Promotional • Special Financing Available font/color/size. Financing • Financing Available

Disclosure depends on if the program credit card name or image is shown in the ad. Advertising Templates If the underlying Promotional Financing offer is a Deferred Interest offer, then the word Promotional or Special must be included in the headline. Why is that? Unlike EPNI and FPRA offers, Deferred Interest promotions are not structured to pay off the purchase within the specific promo period.

Creating a Trigger Sub-headline is not required Term Ad Disclosure Option 1: If the program credit card name or image is not mentioned or shown in the advertisement, then you can simply direct the consumer where to get information. Creating a Combo *See [where] for details. Promo Financing Ad Option 2: If the program credit card name or image is mentioned or shown in the advertisement, use this disclosure. Subject to credit approval. See [where] for details. Creating a Generic Promo [Language in brackets is required but varies]. Financing Ad See the References for examples of pre-approved Generic Headlines

General Guidance General Guidance Click on the circles below to navigate to each topic.

How to Disclose Using Credit Card Qualifying or Name and/or Card Art: Point of Purchase Minimum Purchase When and Why Requirements

Digital

Radio/TV

Everyday Offer Advertising Financing vs Limited Time Social Media with Multiple Financing Financing Offer Providers (Trigger or Combo)

Small/Large Format

Using Credit Card Name and/or Card Art: When and Why General Guidance When advertising trigger term or combo promotions, the sub-headline should include the name of the credit card that must be used to qualify for the promotion, since that Print is a material term of the specific offer.

Point of Purchase

Digital

Radio/TV

Social Media Example is illustration only. Ask your Synchrony representative to provide specific promotion language based on the offer selected, or access Advertising Center at www.synchronybusiness.com

Small/Large Format CONTINUE

Using Credit Card Name and/or Card Art: When and Why General Guidance An alternative to this requirement is to use an image of the credit card itself. This should be in close proximity to the headline so a reasonable consumer would Print understand that the credit card must be used.

Point of Purchase

Digital

Radio/TV

Social Media

Example is illustration only. Ask your Synchrony representative to provide specific promotion language based on the offer selected, or access Advertising Center at www.synchronybusiness.com Small/Large Format BACK CONTINUE

How to Disclose Qualifying or Minimum Purchase Requirements General Guidance When advertising trigger term or combo promotions, the sub-headline should include the minimum purchase amount and qualifying products (if applicable), since these are Print material terms of the specific offer.

For qualifying products, it would be Point of Purchase worded:

On [insert product limitations] Digital purchases [of $XXX or more] made with your Retailer X credit card.

Radio/TV

Example is illustration only. Ask your Synchrony to provide specific promotion language based on the offer selected, or access Advertising Center at Social Media www.synchronybusiness.com

Small/Large Format BACK CONTINUE

How to Disclose Qualifying or Minimum Purchase Requirements General Guidance The qualifying or minimum purchase text can be removed from the sub-headline if:

Print Financing is available with no specific or minimum purchase, and all purchases on the credit card are given Point of Purchase the financing offer.

Digital

Example is illustration only. Radio/TV Ask your Synchrony representative to provide specific promotion language based on the offer selected, or access Advertising Center at www.synchronybusiness.com

Social Media

Small/Large Format BACK CONTINUE

Everyday Offer vs Limited Time Financing Offer (Trigger or Combo) General Guidance

For a limited time promotion, the following guidelines apply: Print • When advertising trigger term or combo promotions, the sub- headline should include the Point of Purchase date range the offer is available, since that is a material term of the specific offer. Digital • An exception applies if this is an everyday offer on the credit card (and never expires). The Radio/TV date range can be removed from the sub-headline.

• See the trigger term example at Example is illustration only. right. The disclosure can be on Ask your Synchrony representative to provide specific Social Media promotion language based on the offer selected, or access the same page or referenced Advertising Center at www.synchronybusiness.com on a different page (i.e. see back page for details). Small/Large Format BACK CONTINUE

Everyday Offer vs Limited Time Financing Offer (Trigger or Combo) General Guidance

NOTE: When using an everyday offer, Print additional disclosure language should be used, if the retailer wants to reserve the right to change the Point of Purchase offer in the future. (Generic ads do not require this language.)

See combo ad example at right. Digital Example is illustration only. Ask your Synchrony representative to provide specific “We reserve the right to discontinue promotion language based on the offer selected, or access or alter the terms of this offer at Advertising Center at www.synchronybusiness.com Radio/TV any time.”

Social Media

Small/Large Format BACK CONTINUE

Advertising Financing with Multiple Financing Providers General Guidance

When financing promotions from Synchrony Bank and other financial providers (including in-house financing) are mentioned in the same ad, it needs to be clear that Print all promotions are not offered on the credit card issued by Synchrony Bank. This should be done by identifying which lender is providing each offer. Two potential ways to display this information: Point of Purchase • Option 1: Include program name (or financial provider) in the offer sub-headline (if each financial provider has a unique program name) • Option 2: Add name of financing issuer/financial provider to disclosure or offer Digital sub-headline

Please contact your Synchrony representative for further guidance if needed. Radio/TV They will work with you on your unique situation and provide the correct language.

Social Media

Small/Large Format BACK

Print Channel Examples General Guidance Click on the circles below to navigate to each topic.

Print Equal Fixed Deferred Payments/ Payments/ Point of Purchase Interest No Interest Reduced APR

Digital

Radio/TV Multi-Page Combo Offer Generic Offer Advertising Social Media Language Language and Redirects

Small/Large Format

Print Ad – Deferred Interest General Guidance 1 Main Headline (Trigger Term) • Keep font/color the same throughout • See here for approved headline wording options Print 2 Sub-headline • Must be in close proximity to main headline left, right or directly Point of Purchase below headline • Sub-headline must be a reasonable 1 size in relation to headline, clear and conspicuous - 40% of the main headline size could be Digital a good benchmark 2 • Font size and color may vary, but no smaller than 10 pt. 3 Supporting Disclosure Radio/TV • Connects to headline via a disclosure identifier (i.e. asterisk) 3 • Must appear on same page (if single-page ad) or on the reverse side of a one-page ad • Can appear elsewhere on multi-page ads Social Media with redirect from first reference. Example: Example is illustration only. See page XX for details. Ask your Synchrony representative to provide specific • Different promotions or retail products promotion language based on the offer selected, or access should each have their own identifiers and Advertising Center at www.synchronybusiness.com start with a new paragraph if space allows. Small/Large Format • Minimum 8 pt. font size CONTINUE

Print Ad – Equal Payments/No Interest General Guidance 1 Main Headline (Trigger Term) • Reasonable variation allowed in font/color/size • Years may be used in headline (i.e., 3 years interest free financing) Print • If a year (i.e. 2022) is used in a headline, a month must be used with it (i.e. 0% Interest Until January, 2022) • See here for approved headline wording options

Point of Purchase 2 Sub-headline • Must be in close proximity to main headline • Font size may vary but can be no smaller than 10 pt. 1 • Sub-headline must be a reasonable size in relation to headline, clear and conspicuous - 40% of the main 2 Digital headline size could be a good benchmark • Months must be shown in the sub-headline when referring to the number of equal monthly payments required (even if years are shown in headline) Radio/TV 3 Supporting Disclosure 3 • Connects to headline via a disclosure identifier (i.e., asterisk) • Must appear on same page (if single-page ad) or on the Social Media reverse side of a one-page ad • Can appear elsewhere on multi-page ads with redirect Example is illustration only. Ask your Synchrony representative to provide specific from first reference. Example: See page XX for details. promotion language based on the offer selected, or access • Minimum 8 pt. font size Advertising Center at www.synchronybusiness.com • Different promotions or retail products should have Small/Large Format their own identifiers and start with a new paragraph if space allows BACK CONTINUE • Ads with multiple equal pay offers may link to the same disclosure

Print Ad – Fixed Payments/Reduced APR General Guidance 1 Main Headline (Trigger Term) • Reasonable variation allowed in font/color/size • Years may be used in the headline (i.e. 3 years fixed monthly payments) Print • See here for approved headline wording options 2 Sub-headline Point of Purchase • Must be in close proximity to main headline • Font size may vary but can be no smaller than 10 pt. 1 • Sub-headline must be a reasonable size in relation to headline, clear and conspicuous - 2 Digital 40% of the main headline size could be a good benchmark • Months should be shown in the sub-headline when referring to the number of equal monthly payments required (even if years are shown in Radio/TV headline) 3 3 Supporting Disclosure • Connects to headline via a disclosure identifier (i.e., asterisk) Social Media • Must appear on same page (if single-page ad) or on the reverse side of a one-page ad Example is illustration only. • Can appear elsewhere on multi-page ads with Ask your Synchrony representative to provide specific redirect from first reference. Example: See page promotion language based on the offer selected, or access XX for details. Advertising Center at www.synchronybusiness.com Small/Large Format • Minimum 8 pt. font size • Different promotions or retail products should BACK CONTINUE have their own identifiers and start with a new paragraph if space allows

NO TRIGGER TERM (INTEREST RATE/APR) Print Ad – Combo Offer Language WITH PROMO TIMEFRAME (XX Months) General Guidance 1 Main Headline (Combo Type) • Reasonable variation allowed in font/color/size • Years may be used in headline (i.e., 3 Years Promotional Financing) Print • See here for approved headline wording options

2 Sub-headline • Must be in close proximity to main headline Point of Purchase • Sub-headline must be a reasonable size in relation to headline, clear and conspicuous - 40% of the main headline size 1 could be a good benchmark • Font size may vary but can be no Digital smaller than 10 pt. • The minimum purchase required, card name or 2 card art and specific time period offer is available should be in sub-headline • Exception: If a card name or image is not used, a Radio/TV sub-headline is not required 3 Supporting Disclosure 3 • Specific language: *Subject to credit approval. Example is illustration only. Minimum monthly payments required. See store for details. Social Media Ask your Synchrony representative to provide specific • Connects to headline via a disclosure identifier (i.e., asterisk) promotion language based on the offer selected, or access • Must appear on same page (if single-page ad) or on the reverse Advertising Center at www.synchronybusiness.com side of a one-page ad • Can appear elsewhere on multi-page ads with redirect from first Small/Large Format reference. Example: See page XX for details. Minimum 8 pt. font size • BACK CONTINUE • Different promotions or retail products should have their own identifiers and start with a new paragraph if space allows

NO TRIGGER TERM (INTEREST RATE/APR) Print Ad – Generic Offer Language NO PROMO TIMEFRAME MENTIONED General Guidance 1 Main Headline (Generic Type) • Reasonable variation allowed in font/color/size • See here for approved headline wording options

Print Sub-headline • No sub-headline is needed • Optional: Include the fact that the promotional financing is available on a specific credit card Point of Purchase 2 Supporting Disclosure • Specific language (if card name is mentioned): 1 *Subject to credit approval. See store for details. • Connects to headline via a disclosure identifier Digital (i.e., asterisk) 2 • Must appear on same page (if single-page ad) or on the reverse side of a one-page ad Example is illustration only. Ask your Synchrony representative to provide specific • Can appear elsewhere on multi-page ads with redirect from first promotion language based on the offer selected, or access reference. Example: See page XX for details. Advertising Center at www.synchronybusiness.com Radio/TV • Minimum 8 pt. font size • Supporting disclosure can be located with other disclosures • Different promotions or retail products should have their own identifiers and start with a new paragraph if space allows • The generic disclosure and the disclosure symbol (*) are Social Media suggested, but only required when the credit card name or image is mentioned or shown. The ad must still tell the customer where to find details • If there is no mention of the credit card or an image of the credit card, then no disclosure is required when using the Small/Large Format generic headline BACK CONTINUE

Print Ad – Multi-page Advertising and Redirects General Guidance 1 Type of Promotion: Applies to all offer types

Print 2 Redirect Supporting Disclosure • Redirect from first promotional headline and sub- headline • Connects to headline via a disclosure identifier Point of Purchase (i.e., asterisk) and provides direction to where the disclosure is located (i.e. See page XX for details.) 1 • Minimum 8 pt. font size • Make sure each page is numbered, so consumer can find the disclosure easily. Another choice is to Digital use a description (see back page, see front cover, etc.)

Option (front) • Ads with multiple offers of the same type may link Radio/TV to the same disclosure 2

Social Media (back) Example is illustration only. Ask your Synchrony representative to provide specific promotion language based on the offer selected, or access Advertising Center at www.synchronybusiness.com Small/Large Format BACK

Point-of-Purchase Channel Examples General Guidance Click on the circles below to navigate to each topic.

Print Equal Fixed Deferred Payments/ Payments/ Point of Purchase Interest No Interest Reduced APR

Digital

Radio/TV

Combo Offer Generic Offer Social Media Language Language

Small/Large Format

Point-of-Purchase – Deferred Interest General Guidance 1 Main Headline (Trigger Term) • Keep font/color the same throughout • See here for approved headline wording options

Print 2 Sub-headline • Must be in close proximity to main headline left, right or directly below headline 1 • Sub-headline must be a reasonable size in relation to headline, clear and conspicuous - 40% of the Point of Purchase main headline size could be a good benchmark 2 • Font size and color may vary, but can be no smaller than 10 pt.

Digital 3 Supporting Disclosure • Connects to headline via a disclosure identifier (i.e., asterisk) • Must appear on same page (if single-page POP) • Can appear elsewhere on multi-page ads with redirect from first reference. Example: See page XX for details. Radio/TV • Minimum 8 pt. font size 3 • Different promotions or retail products should each have their own identifiers and start with a new paragraph if space allows

Social Media Truncated Disclosure: For in-store sign when in-store brochure is readily available with the full disclosure *Regular account terms apply to non-promo purchases and, after Example is illustration only. promo period ends, to the promo balance. For new accounts: Ask your Synchrony representative to provide specific promotion language based on the offer selected, or access Purchase APR is [XX.99%]. Minimum interest charge is [$X]. Existing Advertising Center at www.synchronybusiness.com Small/Large Format cardholders: See your credit card agreement terms. See [insert exactly where in the store the brochure is available] for important details. Subject to credit approval. CONTINUE

Point-of-Purchase – Equal Payments/No Interest General Guidance 1 Main Headline (Trigger Term) • Reasonable variation allowed in font/color/size • Years may be used in headline (i.e., 3 years interest free financing) Print • If a year (i.e. 2022) is used in a headline, a month must be used with it (i.e. 0% Interest Until January, 2022) 1 • See here for approved headline wording options 2 Sub-headline Point of Purchase • Must be in close proximity to main headline • Font size may vary but can be no smaller than 10 pt. • Sub-headline must be a reasonable size in relation 2 to headline, clear and conspicuous - 40% of the main headline size could be a good benchmark Digital • Months must be shown in the sub-headline when referring to the number of equal monthly payments required (even if years are shown in headline) 3 Supporting Disclosure 3 Radio/TV • Connects to headline via a disclosure identifier (i.e., asterisk) • Must appear on same page (if single-page POP) • Can appear elsewhere on multi-page ads with redirect from first reference. Example: See page XX for details. Minimum 8 pt. font size Social Media • • Different promotions or retail products should have their own identifiers and start with a new paragraph if space allows Example is illustration only. Ask your Synchrony representative to provide specific promotion language based on the offer selected, or access See next page for Truncated Disclosure Advertising Center at www.synchronybusiness.com Small/Large Format BACK CONTINUE

Point-of-Purchase – Equal Payments/No Interest General Guidance Truncated Disclosure: For in-store sign when in-store brochure is readily available with the full disclosure The monthly payments equal the initial total promo purchase amount divided by the number of months in the promo period, Print rounded up to the next whole dollar. Regular account terms apply to non-promo purchases. For new accounts: Purchase APR is [XX.99%]. Minimum interest charge is [$X]. Existing cardholders: See your credit card agreement terms. See [insert Point of Purchase exactly where in the store the brochure is available] for details. Subject to credit approval.

Digital

Radio/TV

Small/Large Format BACK CONTINUE

Point-of-Purchase – Fixed Payments/Reduced APR General Guidance 1 Main Headline (Trigger Term) • Reasonable variation allowed in font/color/size • Years may be used in the headline (i.e. 3 years fixed monthly payments) Print • See here for approved headline wording options 1 2 Sub-headline • Must be in close proximity to main headline • Font size may vary but can be no smaller than 10 pt. Point of Purchase • Sub-headline must be a reasonable size in relation to headline, clear and conspicuous - 40% of the main 2 headline size could be a good benchmark • Months must be shown in the sub-headline when referring to the number of equal monthly payments required (even Digital if years are shown in headline) 3 Supporting Disclosure • Connects to headline via a disclosure identifier (i.e., asterisk) 3 • Must appear on same page (if single-page POP) Radio/TV • Can appear elsewhere on multi-page ads with redirect from first reference. Example: See page XX for details. • Minimum 8 pt. font size • Different promotions or retail products should have their own identifiers and start with a new paragraph if space allows Social Media Example is illustration only. Truncated Disclosure: For in-store sign when in-store brochure is Ask your Synchrony representative to provide specific readily available with the full disclosure promotion language based on the offer selected, or access The monthly payments are equal to [X.XX%] of initial total promo purchase Advertising Center at www.synchronybusiness.com Small/Large Format amount and rounded up to the next whole dollar. Regular account terms apply to non-promo purchases. For new accounts: Purchase APR is [XX.99%]. Minimum interest charge is [$X]. Existing cardholders: BACK CONTINUE See your credit card agreement terms. See [insert exactly where in the store the brochure is available] for details. Subject to credit approval. © 2020 Synchrony Financial. All rights reserved. No reuse without prior written consent from Synchrony Financial. Home Understanding Offer Channel Monthly Payment Additional the Guidelines Descriptions Examples Advertising Guidance

Point-of-Purchase – Combo Offer Language General Guidance NO TRIGGER TERM (INTEREST RATE/APR) WITH PROMO TIMEFRAME (XX Months) 1 Main Headline (Trigger Term) • Reasonable variation allowed in font/color/size Print • Years may be used in headline (i.e., 3 years Promotional Financing Available) • See here for approved headline wording options

Point of Purchase 2 Sub-headline • Must be in close proximity to main headline 1 • Sub-headline must be a reasonable size in relation to headline, clear and conspicuous - 40% of the main headline size could be a good benchmark Digital • Font size may vary but can be no smaller than 10 pt. • The minimum purchase required, card name or art image and specific time period offer is available should be in 2 sub-headline • Exception: If a card name or image is not used, a sub- Radio/TV headline is not required

3 Supporting Disclosure • Specific language: 3 *Subject to credit approval. Minimum monthly payments Social Media required. See store for details. Example is illustration only. • Connects to headline via a disclosure identifier (i.e., asterisk) Ask your Synchrony representative to provide specific • Must appear on same page (if single-page POP) promotion language based on the offer selected, or access Advertising Center at www.synchronybusiness.com • Can appear elsewhere on multi-page ads with redirect from Small/Large Format first reference. Example: See page XX for details. Minimum 8 pt. font size • BACK CONTINUE • Different promotions or retail products should have their own identifiers and start with a new paragraph if space allows

Point-of-Purchase – Generic Offer Language General Guidance NO TRIGGER TERM (INTEREST/APR) NO PROMO TIMEFRAME MENTIONED 1 Main Headline (Trigger Term) • Reasonable variation allowed in font/color/size Print

Sub-headline • No sub-headline is needed 1 • Optional: Include the fact that the promotional financing Point of Purchase is available on a specific credit card

2 Supporting Disclosure • Specific language if credit card is mentioned: Digital *Subject to credit approval. See store for details. • Connects to headline via a disclosure identifier (i.e., asterisk) • Must appear on same page (if single-page POP) • Can appear elsewhere on multi-page ads with redirect from Radio/TV first reference. Example: See page XX for details. • Minimum 8 pt. font size • The Generic disclosure and the disclosure symbol (*) are suggested, but only required when the credit card name or 2 image is referenced or shown Social Media • Different promotions or retail products should have their own Example is illustration only. identifiers and start with a new paragraph if space allows Ask your Synchrony representative to provide specific promotion language based on the offer selected, or access Advertising Center at www.synchronybusiness.com

Small/Large Format BACK

Digital Channel Examples General Guidance Click on the circles below to navigate to each topic.

Digital Ads Digital Ads Print General & FTC.com General Guidelines Guidance

Point of Purchase EPNI (Equal Website WPDI (With Combo Offer Generic Offer Payments No Advertising Pay Deferred Language Language Digital Interest) Interest)

Radio/TV Website EPNI (Equal Product Payments No Detail Page Interest)

Social Media Combo EPNI (Equal WPDI (With FPRA (Fixed Digital Web or Generic Payments No Pay Deferred Pay Reduced Banner Ads Small/Large Format Language Interest) Interest) APR)

Digital Ads & FTC.com Guidelines General Guidance When using a hyperlink to lead to a disclosure: • Make the link obvious (e.g. “hyperlink treatment” such as underlined, different color font, etc.) Print • Label the hyperlink appropriately to convey the importance, nature, and relevance of the information it leads to (e.g. “Important Details”, “Learn More”, etc.) • Use hyperlink treatment consistently, so consumers know when a link is available Point of Purchase • Place the hyperlink as close as possible to the relevant information it qualifies and make it noticeable • Take consumers directly to the disclosure on the click-through page (literally “one Digital click away”) • Assess the effectiveness of the hyperlink by monitoring click-through rates and other information about consumer use and make changes accordingly Radio/TV Design advertisements so that “scrolling” is not necessary in order to find a disclosure, if possible. When scrolling is necessary, use text or visual cues to Social Media encourage consumers to scroll to view the disclosure. Scrolling should be vertical, not horizontal.

Small/Large Format CONTINUE

Digital Ads: General Guidance General Guidance If promotional financing or any other offer associated with a specific Synchrony credit card is being advertised on a retailer’s website, then the consumer should be able to take advantage of the offer online or it should be clear that is not the case. If the Print promotional purchase can be made online then the consumer should have access to the full terms of the offer before they make the purchase so that they are able to make an informed decision.

Point of Purchase EMAIL COMMUNICATIONS • All the links in the communication must work Digital • Linked pages must be reviewed for all ads • Required disclosures/supporting information must be one click away or at the bottom of the email Radio/TV • Subject lines must accurately communicate the content of the email, be true statements and be submitted with the email for legal review • Emails sent by Synchrony Bank should have the appropriate servicing or marketing Social Media footer – See the applicable job aide. Note – for servicing emails, marketing content cannot comprise more than one third of the overall email content and cannot be more prominent than the servicing content.

Small/Large Format BACK CONTINUE

Example is illustration only. Website Advertising – Deferred Interest Ask your Synchrony representative to provide specific General Guidance promotion language based on the offer selected, or access 1 Main Headline (Trigger Term) Advertising Center at www.synchronybusiness.com • Keep font/color the same throughout • See here for approved headline wording options Print 2 Sub-headline • Must be connected to main headline left, right or 1 directly below headline • Sub-headline must be a reasonable size in 2 Point of Purchase relation to headline, clear and conspicuous - 40% of the main headline size could be a good benchmark • Font size and color may vary, but no smaller than 10 pt. Digital • If supporting disclosure is NOT shown on same page with headline/sub-headline, then sub- headline must include directions to click here for full details/disclosures Radio/TV 3 Supporting Disclosure • Minimum 8 pt. font size 3

Social Media

Small/Large Format BACK CONTINUE

Website Advertising – Equal Payments/No Interest General Guidance Example is illustration only. 1 Main Headline (Trigger Term) Ask your Synchrony representative to provide specific • Choice of size and color as desired promotion language based on the offer selected, or access Advertising Center at www.synchronybusiness.com • Reasonable variation in font/color throughout • See here for approved headline Print wording options 2 Sub-headline • Must be connected to main headline left, right or 1 directly below headline Point of Purchase • Sub-headline must be a reasonable size in relation to headline, clear and conspicuous - 2 40% of the main headline size could be a good benchmark • No variation in font/color throughout Digital • Minimum 10 pt. font size • If supporting disclosure is NOT shown on same page with headline/sub-headline, then sub- headline must include directions to click here for full details/disclosures Radio/TV 3 Supporting Disclosure • Minimum 8 pt. font size 3

Social Media

Small/Large Format BACK CONTINUE

Website Advertising – Combo Offer Language General Guidance Example is illustration only. NO TRIGGER TERM (INTEREST/APR) Ask your Synchrony representative to provide specific WITH PROMO TIMEFRAME ONLY promotion language based on the offer selected, or access Advertising Center at www.synchronybusiness.com 1 Main Headline (Trigger Term) Print • Reasonable variation allowed in font/color/size • See here for approved headline wording options 1 Sub-headline Point of Purchase 2 • Must be in close proximity to main headline • Sub-headline must be a reasonable size in 2 relation to headline, clear and conspicuous - 40% of the main headline size Digital could be a good benchmark • Font size may vary but can be no smaller than 10 pt. • Exception: If a card name or image is not used, a sub-headline is not required Radio/TV 3 Supporting Disclosure • Minimum 8 pt. font size If purchase CANNOT be made online: • Either include supporting disclosure on same page or have the 3 Social Media following disclosure one click away *Subject to credit approval. Minimum monthly payments required. See store for details. If purchase CAN be made online: Small/Large Format • The full headline/sub-headline and disclosure applicable to promotional ad type must be no more than one click away. (This is a deferred interest example.) BACK CONTINUE NOTE: Store/website must have full details available

Website Advertising – Generic Offer Language Example is illustration only. General Guidance Ask your Synchrony representative to provide specific NO TRIGGER TERM (INTEREST/APR) promotion language based on the offer selected, or access NO PROMO TIMEFRAME MENTIONED Advertising Center at www.synchronybusiness.com 1 Main Headline Print • Reasonable variation allowed in font/color/size

Sub-headline 1 • No sub-headline is needed • Optional: Include the fact that the promotional Point of Purchase financing is available on a specific credit card 2 Supporting Disclosure • Minimum 8 pt. font size

Digital If purchase CANNOT be made online: • Either include supporting disclosure on same page or have the following disclosure one click away: *Subject to credit approval. Minimum monthly payments required. See store for details. Radio/TV • If there is no mention of the credit card or no image of the credit card, then no disclosure is required when using this generic headline 2

Social Media If purchase CAN be made online: • The full headline/sub-headline and disclosure applicable to promotional ad type must be no more than one click away. (This is a deferred interest example.) Small/Large Format NOTE: Store/website must have full details available BACK CONTINUE

Website Product Detail Page General Guidance Example is illustration only. Promotion Type: Ask your Synchrony representative to provide specific EQUAL PAYMENTS/NO INTEREST promotion language based on the offer selected, or access Advertising Center at www.synchronybusiness.com 1 Main Headline (Trigger Term) Print • May be trigger term, combo or generic • Reasonable variation in font size and color • Years may be used in headline if months are in sub- headline (equal payments or fixed payments) If a year is used (i.e. 2022) then a month must also be Point of Purchase • used (i.e. 0% Interest until January, 2022)

2 Sub-headline • Must be in close proximity to the headline Digital • Sub-headline must be a reasonable size in relation to headline, clear and conspicuous -40% of the main headline size could 1 be a good benchmark 2 • Months must be shown in the sub-headline when Radio/TV referring to the number of equal/fixed monthly payments (even if years are shown in the headline) • Exception: If card image is used, card name is 3 not required in sub-headline Social Media 3 Supporting Disclosure • Full disclosure of offer must be one click away. NOTE: This is an equal payments/no interest example Small/Large Format BACK CONTINUE

Digital Web Banner Ads – Combo / Generic (all offer types) General Guidance Combo Combo 1 Main Headline (with card art) (no card art) Sub-headline Print 2 • Exception: For combo headlines, if the card name/image is not present, a sub-headline is not 1 required • Must be in close proximity to the headline Point of Purchase 1 • Sub-headline must be a reasonable size in relation to headline, clear and conspicuous - 40% of the main headline size could be a good benchmark 2 3 • Full sub-headline for trigger and combo promotions • Exception: In limited space situations, truncated Digital sub-headlines may be used as shown, with full details 3 one-click away • Exception: If credit card is not shown, then card Generic Generic name must be included in the sub-headline (with card art) (no card art) Radio/TV 3 Supporting Disclosure • Disclosures must be on the same page or one-click away 1 Example is illustration only. Ask your Synchrony representative to provide specific promotion Social Media language based on the offer selected, or access Advertising Center at www.synchronybusiness.com 1

Small/Large Format 3 3 BACK CONTINUE One-click to finance page for all offer types

Digital Web Banner Ads – EPNI (Equal Pay No Interest) General Guidance 1 Main Headline (Trigger Term) 1 Print 1 2 Sub-headline 2 • Must be in close proximity to the 2 headline • Sub-headline must be a 3 reasonable size in relation to Point of Purchase headline, clear and conspicuous - 3 40% of the main headline size could be a good benchmark 1 • Exception: In limited space Digital situations, truncated sub- headlines may be used as shown, 3 with full details one-click away 2 • Exception: If credit card is not (1-CLICK AWAY) shown, then card name must be

Radio/TV * No interest will be charged , and equal monthly payments are required on promo purchase until it is paid in full. The payments equal the initial total promo purchase amount divided by the number of months in the promo period, rounded up to the next whole dollar. These payments may be higher than the payments that would be required if this purchase Supporting Disclosure Social Media was a non-promo purchase. Regular account terms apply to non-promo purchases. [Insert New Account 3 APR/Minimum Interest Charge]. Existing cardholders: See your credit card agreement terms. • Disclosures must be on the Subject to credit approval. same page or one-click away One-click to finance page for all offer types Small/Large Format Example is illustration only. Ask your Synchrony representative to provide specific promotion language based on the offer selected, or access BACK CONTINUE Advertising Center at www.synchronybusiness.com

Digital Web Banner Ads – WPDI (With Pay Deferred Interest) General Guidance Example is illustration only. Ask your Synchrony representative to provide specific promotion language based on the offer selected, or access Advertising Center at www.synchronybusiness.com Main Headline Print 1 1 1 (Trigger Term) 2 Sub-headline 2 • Must be in close proximity to the 2 headline Point of Purchase 3 • Sub-headline must be a reasonable size in relation to headline, clear and 3 conspicuous - 40% of the main 1 headline size could be a good benchmark Digital • Exception: In limited space 3 situations, truncated sub-headlines 2 may be used as shown, with full (1-CLICK AWAY) details one-click away. No interest if paid in full within [XX] months* Example of full headline /subheadline Radio/TV On purchases made with your [name of 2 credit card] . Interest will be charged to your account from the purchase date if the needed in this situation is in red. promotional balance is not paid in full [within XX Months] [by Month, Year]. <$29 account activation fee [may/will] apply.> Minimum monthly payments required. • Exception: If credit card is not shown, then card name must be included in * No interest will be charged on the promo balance if you pay it off, in full, within the promo period. If you do not, interest will be charged on the promo balance from the purchase date. The required minimum monthly payments may or page or one-click away Small/Large Format may not pay off the promo balance before the end of the promo period, depending on purchase amount, promo length and payment allocation. Regular account terms apply to non-promo purchases and, after promo period ends, to the promo balance. [, except that the fixed monthly payment will continue to be required until the promotion is paid in full. Insert New Account APR/Minimum Interest Charge]. Existing cardholders: See your credit card agreement terms. Subject to credit approval. BACK CONTINUE One-click to finance page for all offer types © 2020 Synchrony Financial. All rights reserved. No reuse without prior written consent from Synchrony Financial. Home Understanding Offer Channel Monthly Payment Additional the Guidelines Descriptions Examples Advertising Guidance

Digital Web Banner Ads – FPRA (Fixed Pay Reduced APR) General Guidance Example is illustration only. Ask your Synchrony representative to provide specific promotion language based on the offer selected, or access Advertising Center at www.synchronybusiness.com Main Headline Print 1 1 1 (Trigger Term) 2 2 Sub-headline • Must be in close proximity to the 2 headline Point of Purchase 3 • Sub-headline must be a reasonable size in relation to headline, clear and 3 conspicuous - 40% of the main 1 headline size could be a good benchmark Digital • Exception: In limited space 2 3 situations, truncated sub-headlines (1-CLICK AWAY) may be used as shown, with full details one-click away. XX.99% APR with XX fixed monthly payments* Example of full headline /subheadline Radio/TV On made with your [name of credit card] . <$29 account activation fee [may/will] apply.> • then card name must be included in * Interest will be charged on the promo purchase from the purchase date at a reduced [XX.XX%] APR, and fixed monthly payments are required until paid in full. These payments are equal to X.XX% of initial total promo purchase amount, rounded up to the next whole Supporting Disclosure dollar. These payments may be higher than the payments that would be required if this purchase was a non- 3 promo purchase. Regular account terms apply to non-promo purchases. [Insert New Account APR/Minimum • Disclosures must be on the Interest Charge]. Existing cardholders: See your credit card agreement terms. Subject to credit approval. same page or one-click away Small/Large Format One-click to finance page for all offer types BACK

TV or Radio/Broadcast Channel Examples General Guidance Click on the circles below to navigate to each topic.

Print General Visuals & Audio Additional Guidance

Point of Purchase

Radio Trigger Term Combo Offer Digital Examples Language

Radio/TV Equal Payments Fixed Payments /No Interest /Reduced APR (Trigger Term) (Trigger Term) Social Media TV Deferred Interest Examples (Trigger Term) Equal Payments Fixed Payments Small/Large Format /No Interest With /Reduced APR With Monthly Payments Monthly Payments

TV or Radio/Broadcast Ads General Guidance Visuals (TV) • Disclosures cannot be obscured by graphics, shading, coloration or other ways. Disclosures must be displayed so a Print consumer can reasonably see and read the information.

Point of Purchase Example is illustration only. Ask your Synchrony representative to provide specific promotion language based on the offer selected, or access Advertising Center at www.synchronybusiness.com Digital Audio • Whether via radio, television or other broadcast, the required disclosures must be given at a speed and volume sufficient Radio/TV for a consumer to hear and understand them. • Speed and volume should be similar to the rest of the commercial content.

Social Media

Small/Large Format CONTINUE