We have a new product out that, while not directly targeted at minors, is a good product for high school seniors and juniors who are starting accounts. We have a small group of 16-18 year old customers who we were looking at possibly just sending a letter about the account to.

I've searched quite a bit and can't seem to come up with much information regarding laws and/or regulations about it.

Does anyone else have experience in this territory?

We're also in Illinois if state laws make a difference. I have found a bit of info stating that state laws may govern this. However, I can't seem to locate any state laws.

If they are not of age how are they going to enter into a contract? I assume you are talking about a deposit account.

Yes. We would require an adult to be on it with them.

Our new program aside, here is the best way to look at it:

We have adults that most likely have a DDA with us. They also have a minor that is 16 or 17 on a minor savings. We'd like to market to the minors to make the transition into having a DDA with the parent.

One thing that isn't a concern is COPPA. It's scope is limited to kids under 13.

Parent on the account or not - having a minor on the account is a State law issue.

Reviving this.

Marketing wants to place an ad in a local yearbook. The ad is addressed to the faculty, staff and students (which of course is going to include minors). I have searched the state laws and found nothing and can't really think of any Federal regulation that would apply (the advertisement is for a service - mobile banking app).

Does anyone know of any guidance that has been published regarding marketing to minors?

First. How can a minor contract in your State? Get your legal counsel involved.

Nothing is 'signed'. Like most online contracts, you just click on "I accept" without reading it.

But that is something I hadn't thought of. I don't think there is any age restriction in our current agreement; so as long as you have an account, you can get the app.

How do these minors even get the underlying deposit account to begin with???


"I don't think there is any age restriction in our current agreement"

Then you probably have a huge potential COPPA problem.

Our policy is to have an adult on a checking account with a minor. Since technically you can't overdraw a savings account, we will occasionally make an exception for a minor close to majority to have a savings account in their name alone. The app will work for any account, so if a 17 year old has a savings account in just their name, they could get the app. You don't need a checking account to get the app. Therefore my original question about anyone knowing about any guidance or best practices when marketing to minors. Minors are not the target audience necessarily, but an ad in a yearbook will be noticed by minors and I would like to avoid any potential pitfalls if at all possible.

From the lack of response, I would say there probably isn't any out there that anyone is aware of. Sorry to have bothered you.

You cannot contract with minors in most States. So you are asking questions that only your legal counsel an answer.