I am needing to know all of the disclosure requirements for having a newspaper ad that states "Switch your account Get $100.00 It's that simple."

We are wanting to capture, hopefully some of the customers that will have no home after a local bank closes in our area.

Also, would it be ok just to say "Switch your account Get $100.00 It's that simple." and "Call us at (phone #) or come in for details" instead of having any disclosures about the details so to keep the ad short?

If they need details to figure out how to do it other then showing up and opening an account, then IMHO your ad would be deceptive.

That's a pretty hefty price to pay for someone coming in and opening an account for $1.

We will disclose the full details. I believe this is the way to go anyway. Marketing just likes to push the lines a little with some of there ads.

Thanks for your help.

Minimum balance required to open? Minimum balance required to maintain? Any monthly service charges attached to this account? Does the account have to stay open for any period of time to get the $100 or can they close the next day?

If the answer to any of these is yes, the ad would be viewed as deceptive if without the footnotes explaining the requirements to get the hundred.

I hope the minimum balance is about $70,000 and the minimum time to remain on deposit is about one year, because that is what $100 will buy you at the Fed window.

We are going to disclose the details in the ad, however i have seen other banks display ads like this one and just put "Call for details" or "Drop by and visit us for more details" in the ad instead of the footnote disclosures. Why would some banks do this?

Stupid question i know. I would just like to know the negatives to share with others in the future.

Thanks.

Well, being cited for a UDAAP for one by the regulators and then requiring you to give anyone that opened an account while the ad was running $100 is probably not out the question.

Alright, Two more question and then i am done for now...:)

1. Is there anything wrong with us targeting specific customers from the bank that is closing?

2. Also, could we only include those folks in a chance to win a gift card? (Those who cross over from the closing bank)

We are in Texas so i am needing to know about those state law affecting that drawing as well if possible.

1. No, banks target market all the time.

2. Lottery considerations would come into play. You could not limit it and no purchase necessary would be required. (That's not a Texas issue)

Great!

Thanks again for your time and help.