12/08/2008
We'd like to add a link to our website to advertise some of our repossessed mortgages. I've been searching for compliance issues regarding this, but have come up empty. Any ideas? Is this an acceptable practice?
11/24/2008
Our grocery store branches have limited floor space. During the day they can move some signs to the walkway in front of the branch and at night, pull them back in before the gate is lowered. For ease of use and to vary the product offerings they are using whiteboards and people with really nice penmanship. What compliance problems are there with whiteboards?
08/25/2008
I have recently taken over the compliance role for our banks internet banking department. I understand that when we are advertising securities products, we have to ensure that consumers are aware the product is not FDIC insured and may lose value. Our product marketing team utilizes banners on our website pages for advertising purposes. Of course I would prefer that banners advertising FDIC insured products not be allowed for pages advertising non-FDIC products such as insurance and securities. Are there regulations to support my preference. If so can you provide them to me, or should I allow both product types on the same internet page as long as the disclaimers specifically explain the FDIC coverage?
08/18/2008
What are the penalties if a bank goofs up and places a loan ad in the paper that says $500 down and leaves off the proper disclosures that are required for trigger terms?
07/14/2008
We would like to post a banner at the bank advertising free business checking. Can we advertise free business checking if the account is not totally free? If they exceed the monthly check total or have overdrafts there will be fees. The account is free up to 250 checks, so I can see where we would advertise free. It is free within the guidelines addressed when opening the account. I just want to make sure that we will be in compliance if we do this.
07/14/2008
If we develop in-house lobby flyers advertising mortgage loans would the same disclosures apply that apply to newspaper print ads?
07/07/2008
Since web sites have widely varying degrees of functionality, each bank must determine its own obligation. It's been a long time since I've seen a bank web site that isn't at least an advertisement. Catalog the products that will be promoted there and then aggregate the advertising regulations that apply to those products. If you offer online applications, then add the rules that apply up to that stage. If you also provide online decisions, then add the additional rules that come into play. If you go all the way and open the new loan/deposit online, keep adding the additional rules that apply during all stages of a customer relationship. There are very few rules that are uniquely Internet-related and not tied to a product. Included in this short list are "speed bumps," CAN-SPAM, and COPPA.
06/09/2008
Are there any compliance concerns in any area for advertising that "we will give you $20 if you come into our bank and no one speaks to you or should we not respond to your request within a reasonable period of time"? This is applicable to everyone alike - customers and non-customers.
06/02/2008
We have flyers out at a local motorcycle dealership advertising our bank as a possible choice in financing a bike. The dealer has asked if they can receive a referral fee for loans that close at our bank. RESPA states that this is not allowed for dwelling loans, but is acceptable for non-dwelling. How do we list the charge on the loan document?
03/17/2008
I am fairly new to the deposit compliance arena. Under the advertising section of Reg DD, there are exemptions for certain types of media (<a href="http://www.bankersonline.com/regs/230/230-8.html">230.8(e)</a>). One of these exemptions is broadcast or electronic media, such as television or radio. Would an advertisement on our bank's website be categorized as electronic media, and thus exempt from certain disclosure requirements, or would it be considered just like print media and thus be subject to all requirements of <a href="http://www.bankersonline.com/regs/230/230-8.html">230.8(c)</a>? I think that it should be treated just like print media, but I am having a difficult time finding any regulatory guidance to either confirm or refute this.