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#2175825 - 04/30/18 03:50 PM reward checking brochures
Bec Offline
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Bec
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Posts: 1,115
The Great White North
We have a couple of checking products where the service charge will be waived if you meet several requirements. EX $10 dollar service charge waived if you have direct deposit or 10 debit card transactions/month posted and cleared, etc.
If we are just creating a brochure, would you have to put terms and qualifications on the brochure if there are no triggering terms that would make it an ad? Or could you say "please call or stop in for details"?
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#2175826 - 04/30/18 03:52 PM Re: reward checking brochures Bec
rlcarey Online
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rlcarey
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Galveston, TX
What are you saying in the brochure, that the normal service charges may be waived under specific circumstances?? I guess I don't understand the question?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2175834 - 04/30/18 04:14 PM Re: reward checking brochures Bec
Adam Witmer Offline
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Originally Posted By Bec
If we are just creating a brochure, would you have to put terms and qualifications on the brochure if there are no triggering terms that would make it an ad?

I say this without seeing your actual brochure, but excluding any fee waiving (or rewards earning) qualifications on advertisements could have UDAAP implications.
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#2175838 - 04/30/18 04:24 PM Re: reward checking brochures Bec
Bec Offline
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Bec
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The Great White North
The brochure, as it exists now, includes the name of the checking account and a couple of high level description bullet points.
For example:
EZ Checking
- A no-hassle checking account to fit your financial needs
- Rebate of ATM fees up to $10 per Statement Cycle

Best Interest Checking
- Designed for debt card, direct deposit, and online banking users to earn a premium interest rate.
- Rebate of ATM fees up to $15 per statement cycle.

My thought is that we need disclosure language on the brochure to indicate specifically what the reader has to do in order to obtain these benefits. But would it be acceptable to put a "call bank for further details" line on the brochure?
Last edited by Bec; 04/30/18 04:29 PM.
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#2175854 - 04/30/18 05:19 PM Re: reward checking brochures Bec
rlcarey Online
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rlcarey
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Galveston, TX
If you talk about rebates and don't want a UDAAP issue, it better be fully explained in the brochure.
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#2175855 - 04/30/18 05:20 PM Re: reward checking brochures Bec
Bec Offline
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Bec
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The Great White North
Thank you for the feedback. Almost forgot my follow up question. There are no rates listed on the brochures, but there are references to interest bearingness on the brochure. Would that be enough to make one spell out the different earnings, tiers, etc? I think my marketing person is not going to be my friend after this one.
Last edited by Bec; 04/30/18 05:23 PM.
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#2175860 - 04/30/18 05:29 PM Re: reward checking brochures Bec
rlcarey Online
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rlcarey
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Galveston, TX
No - the statement that the account is interest bearing is not a trigger term.
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