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#2096836 - 09/02/16 05:40 PM MOBILE BANKING UPGRADE AD
ComplianceGurl, CRCM Online
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Joined: Jul 2007
Posts: 498
Hello,
We are in the process of upgrading our online banking, including our mobile banking app to allow mobile remote deposit for consumers. We will be sending out a notice to our current online/mobile banking customers of this news. Other than bank fees (if applicable), fees from their wireless carrier, and a blurb about referring to our Mobile Banking terms and conditions agreement, is there anything else we need? Our external auditor recommended adding something about our Hold Policy for mobile banking customers, however, this is not something we would include in a checking account ad so it seems like overkill? I can't seem to find any rules on advertising a product like this? Thoughts? Can anyone shed some light on what is required?
Thank you!!

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#2096847 - 09/02/16 06:03 PM Re: MOBILE BANKING UPGRADE AD ComplianceGurl, CRCM
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,617
Galveston, TX
Our external auditor recommended

The only recommendations you should be listening too are those from your legal counsel.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2096855 - 09/02/16 06:12 PM Re: MOBILE BANKING UPGRADE AD ComplianceGurl, CRCM
ComplianceGurl, CRCM Online
Gold Star
Joined: Jul 2007
Posts: 498
Thank you Randy for your feedback. We are a very small bank and sometimes if I have a compliance question I get an opinion from our external auditors who annually review our advertisements. We don't have legal counseling on stand-by to approve our marketing materials. I was only questioning if someone knew what the guidelines were for advertising mobile deposit.
Last edited by ComplianceGurl; 09/02/16 06:23 PM.
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#2096901 - 09/02/16 09:23 PM Re: MOBILE BANKING UPGRADE AD ComplianceGurl, CRCM
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,617
Galveston, TX
There are none, unless you are hitting specific triggers, like Reg. DD.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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