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#175570 - 04/01/04 04:11 PM Brochure disclosures vs. Lobby disclosures
Mike Baker Offline
100 Club
Mike Baker
Joined: Dec 2002
Posts: 192
Tennessee
We have a products brochure in which we disclose fees, including those of our safe deposit boxes. It turns out that we have at least one branch, our newest one, that was told from its first day to charge a higher price than our other branches. Their "Lobby board" discloses the correct prices for the boxes at their branch. My feeling is that the brochures at that branch should have the charges corrected, either by marking through or stapling an insert [both temporary fixes] until new brochures can be printed. However, one of our bank officers is wanting to know exactly where in the regulations that it states that our brochures must match what is posted in the lobby. So far I haven't come across anything that specifically states that as such, but I feel like that they should match in order not to be deceptive in disclosing our product pricing...plus I would not want an examiner to walk in that branch and find that discrepancy. Could someone point me to something specific that would make my case...or am I wrong that this is a legitimate concern?
_________________________
"When you believe He's all you need,that will be your defining moment." [from "Defining Moment" Newsong, Sheltering Tree CD]

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#175571 - 04/01/04 08:51 PM Re: Brochure disclosures vs. Lobby disclosures
Anonymous
Unregistered

Try "Unfair & Deceptive Banking Practice" with a written complaint to the president of your bank and your regulator.

If I was a new customer visiting your branch and picked up a brochure to read about the pricing of your safe deposit boxes and then went to the vault area to rent a box only to be told that the prices were higher (despite being posted on your lobby board which I may have missed viewing). Telling me the higher prices are posted on the lobby board wouldn't make me happy. This is not the way to do business especially in a new branch. Either get rid of the incorrect brochures or revise them. I wouldn't mark through or staple an insert. It doesn't look good. The image of your bank should always be professional.

Mike, your gut feeling is correct - do the right thing!

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#175572 - 04/01/04 09:30 PM Re: Brochure disclosures vs. Lobby disclosures
Mike Baker Offline
100 Club
Mike Baker
Joined: Dec 2002
Posts: 192
Tennessee
The question was posed to me through a 3rd party, who had talked with the bank officer. After conveying the answer provided in the "Compliance" section [which essentially said that it would be perceived as a deceptive practice] to both of them, the bank officer then responded that in reality the question was whether the [to be revised] brochure needed to disclose the charges at all...to me a whole different matter which could be resolved simply by stating something to the effect "Please consult any customer service specialist to obtain more information about the sizes of boxes available and the annual rental charges." That certainly would be general information which would not conflict with any information posted on the lobby board.
I agree about having the brochures look professional...it's just that in the very short term, I would rather provide a brochure that has had information changed to reflect what is accurate than to provide one that is wrong...which it still would be in this case.
In any case, thanks for your input and support!
_________________________
"When you believe He's all you need,that will be your defining moment." [from "Defining Moment" Newsong, Sheltering Tree CD]

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#175573 - 04/16/04 08:10 PM Re: Brochure disclosures vs. Lobby disclosures
Anonymous
Unregistered

Here's what appears in the fine print on the back of our brochures: This brochure is for marketing purposes and is not designed as a substitute for full account disclosure as defined by the Truth in Savings Act. If you are interested in obtaining full disclosure of any product described in this brochure, please contact a customer service representative.

Seems like mgmt. wants to increase fees every few months so I finally got smart and stopped putting our fees on the brochure. We haven't had any complaints.

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