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#1661660 - 02/07/12 07:00 PM Refer-a-Friend Checking Acct Promo and Privacy Act
BLPage Offline
100 Club
Joined: Jan 2006
Posts: 222
Virginia
I understand the privacy issues surrounding the bonus paid on a refer-a-friend checking account promotion.

In order to get around this, I've been told that we can obtain the new customer's acknowledgement that the referring customer will be advised that they, the new customer, is now a bank customer.

QUESTION: Is it sufficient to have a disclaimer on the promo "take one" brochure titled "Important Privacy Notice" that states the referring existing customer may know that the referred friend [new customer] opened a qualifying account?

I think not; I would prefer the new customer's signature of acknowledgement, and would appreciate a third party viewpoint.


Thank you.

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Lending Compliance
#1661775 - 02/07/12 10:12 PM Re: Refer-a-Friend Checking Acct Promo and Privacy Act BLPage
Funky Falcon Offline
100 Club
Joined: Jan 2008
Posts: 242
Minnesota
We have the new customer sign a waiver of acknowledgement at account opening.

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#1661878 - 02/08/12 02:03 PM Re: Refer-a-Friend Checking Acct Promo and Privacy Act BLPage
BLPage Offline
100 Club
Joined: Jan 2006
Posts: 222
Virginia
That is exactly what I feel we should do, but Marketing is overriding Compliance and is just writing a disclaimer.

Thanks for your advice. I'll use it the next time around with this promo.

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#1661895 - 02/08/12 02:25 PM Re: Refer-a-Friend Checking Acct Promo and Privacy Act BLPage
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
How can Marketing override Compliance?
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My Opinions Only

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#1661960 - 02/08/12 03:30 PM Re: Refer-a-Friend Checking Acct Promo and Privacy Act BLPage
Judy G Offline
Junior Member
Joined: Sep 2005
Posts: 40
Somewhere out there
Ahhh, the tsil is wagging the dog smile

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#1662027 - 02/08/12 04:41 PM Re: Refer-a-Friend Checking Acct Promo and Privacy Act BLPage
BLPage Offline
100 Club
Joined: Jan 2006
Posts: 222
Virginia
The only thing we can do is copy sr mgmt on our acknowledgement of their override. If they want to intercede, they will.
As the adage goes, compliance mitigates, but doesn't eliminate risk..... and Skittles ----- like you say, "Nobody listens anyway ..."

See my other inquiry about new checking accts and PCs - discrimination ? Marketing doesn't agree and is again going their own way.

Many thnks for your input.

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