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April 16
Handling ACH Origination Exception Issues
Shelly Simpson

April 17
Fair Lending - Internal Monitoring
Patricia Cashman

April 22
A Banker's Guide to Virtual Currency
Andrew Beal

April 24
BSA/AML Compliance: Writing the SAR Narrative
Ken Golliher

April 29
HSA Basics
Whitney Johnson

April 29
Required Training for Loan Originators
Mary Beth Guard and Jack Holzknecht



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#1666409 - 02/16/12 02:08 PM Ad for bonus without specific account info
CC Poppy Offline
New Poster

Registered: 05/04/06
Posts: 15
If we are advertising bonuses when opening checking account, does the statement "receive $ 100 bonus when you open any checking account" trigger the bonus disclosures? Lets say we change the statement to just "receive a bonus for opening any checking account" does that trigger the bonus disclosures?

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Marketing
#1666451 - 02/16/12 02:52 PM Re: Ad for bonus without specific account info [Re: CC Poppy]
Bob The Banker Offline
Platinum Poster

Registered: 05/17/10
Posts: 958
Reg DD 1030.8 Advertising:
(d) Bonuses. Except as provided in paragraph (e) of this section, if a bonus is stated in an advertisement, the advertisement shall state the following information, to the extent applicable, clearly and conspicuously:

Reg DD 1030.8 Advertising Commentary:
(d) Bonuses.
1. General reference to “bonus.” General statements such as “bonus checking” or “get a bonus when you open a checking account” do not trigger the bonus disclosures.

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With that being said, what is the advertising medium? If the advertisement is indoor sign (signs inside the premises of a depository institution), then the 1030.8(d) Bonus disclosures are not required. Rather, a statement to contact an employee about terms and fees would suffice.

Furthermore, if you have such a large giveaway such as $100 bonus, why would you not want to mention it in your advertisement? Seems to defeat the purpose of advertising the promotion just for the sake of not having to do the work of writing the triggered disclosures.


Edited by Bob The Banker (02/16/12 02:54 PM)

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