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Mailing Info on Bounce Protection
Ken Golliher, BOL Guru
Guru Bios
Question: Regarding Reg. DD changes concerning bounce protection programs - we do not promote our bounce protection program and new customers may become eligible after 30 days. At this time they are mailed information explaining the program. Is this considered promotion and therefore would trigger the additional disclosures on statements?
Answer: Yes, that's promotion and it would trigger the bulk of the new requirements. An ODP mechanism could be put in place without the customers' knowledge (many banks do it this way). The sole purpose of the mailing is to encourage the customer to use the service; it's promotion.
First published on BankersOnline.com 1/23/06
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