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#2193417 - 09/21/18 07:30 PM Not advertising all bank products
LetsTalkCompliance Offline
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There are 4 checking account products our bank wants to push. There are 2 other checking accounts we do not want to push and possibly eliminate, but those product elimination discussions are above me.

Does anyone advertise on their website "featured" products, but does not list all of their products? We've contemplated adding language on our website that directs consumers to visit our branches to ask for our complete list of accounts.

UDAAP concerns?

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General Discussion
#2193426 - 09/21/18 08:02 PM Re: Not advertising all bank products LetsTalkCompliance
Rocky P Offline
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Banks feature products all the time.
What i might caution is if the 2 products you do not want to push (and plan to discontinue) might be the ones to serve the non-banked , or primarily interested to minorities - i.e. low/no cost checking accounts, etc.
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#2193431 - 09/21/18 08:13 PM Re: Not advertising all bank products Rocky P
LetsTalkCompliance Offline
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Originally Posted By Rocky P

What i might caution is if the 2 products you do not want to push (and plan to discontinue) might be the ones to serve the non-banked , or primarily interested to minorities - i.e. low/no cost checking accounts, etc.


You've hit the nail on the head. Now is that a CRA concern? UDAAP? We as compliance are doing are research. I welcome any feedback.

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#2193460 - 09/21/18 10:00 PM Re: Not advertising all bank products LetsTalkCompliance
Andy_Z Offline
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It's a CRA issue. Not offering a product isn't UDAP/UDAP as you are not harming them as in charging fees for products or services they can't use.
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#2193461 - 09/21/18 10:03 PM Re: Not advertising all bank products LetsTalkCompliance
Andy_Z Offline
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I suppose I might add that offering a product to assist CRA is a good thing, unless the bank doesn't want anyone to use it. Then it should be discontinued and the bank needs to know CRA won't be an issue because the problems are resolved, there are no unbanked, etc. If there have been discussions with regulators or community groups about providing these accounts, I'd seriously look at the risk. If its a cost issue, attack it another way. CRA doesn't say you have to lose money.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#2193507 - 09/24/18 01:38 PM Re: Not advertising all bank products LetsTalkCompliance
LetsTalkCompliance Offline
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Joined: Jan 2016
Posts: 61
That's a great way of putting it. I recently called a meeting with compliance, marketing, and retail because as I was completing a TISA compliance review, it was obvious there was a disconnect between marketing and retail about the products we offer (retail was still opening accounts that should have been retired, but wasn't told they were retired). It opened a floodgate and dialogue about products and services, mostly about discontinuing a few account types. Compliance was tasked with assessing UDAAP/CRA risk for discontinuing certain products. I've surprisingly come to the same conclusion about UDAAP, but still researching CRA.

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