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#1385239 - 05/03/10 10:06 PM Advertising - Overdraft protection
Tryin-2-Comply Offline
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Joined: Apr 2003
Posts: 202
Hills of TN
230.11(b)(2) - of REG DD describes the types of communications about the payment of overdrafts that are not subject to additonal advertising disclosures:

(xi) informational or educational materials concerning the payment of overdrafts if the materials do not specifically describe the institutionís overdraft service; or


However, how do you keep informational and educational materials from promoting the prodcut? I've seen other bank's that state: Ask me about our Overdraft courtesy program? Is that not promoting?


How do you specifically describe the service? You overdraw, we pay for a fee.

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Operations Compliance
#1385542 - 05/04/10 04:22 PM Re: Advertising - Overdraft protection Tryin-2-Comply
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,700
Cape Cod
If you're talking about your own program, you have pulled the trigger unless all you are doing is making a mandatory disclosure. But if you're talking about courtesy OD programs in general (using a regulatory agency's brochure, for example), no trigger.
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#1388363 - 05/10/10 03:34 PM Re: Advertising - Overdraft protection John Burnett
GoGreen Offline
Gold Star
Joined: Dec 2007
Posts: 288
PA
I am questioning if we now have ads for our "sweep overdraft protection" offerings are we advertising or can this be just educational? We do charge a fee for the sweep transfer service.

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#1388479 - 05/10/10 05:40 PM Re: Advertising - Overdraft protection GoGreen
Aggs Offline
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Aggs
Joined: Nov 2009
Posts: 1,331
Hoosier Country
Originally Posted By: GoGreen
I am questioning if we now have ads for our "sweep overdraft protection" offerings are we advertising or can this be just educational? We do charge a fee for the sweep transfer service.


You are advertising it if you are actively marketing a specific product/program your bank offers.
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Opinions expressed in these threads are my own and not my employer's.

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#1388615 - 05/10/10 07:40 PM Re: Advertising - Overdraft protection Aggs
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,700
Cape Cod
Education ==> You discuss a generic product or service, never mentioning your own product. It's like discussing the merits and drawbacks of having a NOW account vs. a demand deposit account.

Advertising ==> You discuss your own products or services.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#1389191 - 05/11/10 06:23 PM Re: Advertising - Overdraft protection John Burnett
OnTheEdge Offline
Diamond Poster
Joined: Apr 2002
Posts: 1,677
SmallTown, USA
I'm updating our Deposit Account Brochures. I understand that including the specifics about our ODP will be viewed as advertising. We include info about (1) fees (2) trans. that cause OD (3)repayment requirements (4) and when OD won't be paid. Is there anyting else we need to do?
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