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#1456886 - 10/19/10 06:08 PM UDAP Question
mzachau, CRCM Offline
Gold Star
mzachau, CRCM
Joined: Oct 2006
Posts: 470
San Francisco
Customers who open a new account receive their first set of pre-printed checks for free. This is disclosed in an account brochure maintained in our Branches. We are in the process of developing online account opening, but customers will be charged for their first pre-printed checks if they select checks exceeding $15.

Could this be considered unfair and deceptive? My concern is that we disclose in our brochure that the first box of checks is free and do not specify an amount. Traditionally, we order basic style checks but are unable to limit the style electronically.

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Operations Compliance
#1456926 - 10/19/10 06:51 PM Re: UDAP Question mzachau, CRCM
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
I have typically seen something specifying first order of wallet-style or bank image checks free. If you aren't limiting in the disclosing, it's misleading and you want to clarify.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

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#1456950 - 10/19/10 07:13 PM Re: UDAP Question BrendaC
mzachau, CRCM Offline
Gold Star
mzachau, CRCM
Joined: Oct 2006
Posts: 470
San Francisco
I had the same thought. Thank youf or the response. I also found out we just received a new order of brochures, so it will be difficult to pursuad the change!

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#1456968 - 10/19/10 07:36 PM Re: UDAP Question mzachau, CRCM
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
I have seen labels used to update paragraphs as well as notices stapled to brochures advising of these type clarifications. Doesn't win any presentation awards, but gets the job done until the budget allows for new brochures.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

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#1457384 - 10/20/10 05:04 PM Re: UDAP Question BrendaC
Bob The Banker Offline
Platinum Poster
Bob The Banker
Joined: May 2010
Posts: 958
Easy fix would be insert a asterisk and specify the check order.

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