So historically, the bank has done very little marketing; we are launching a new deposit product and will be doing some target marketing of this product. We are using a vendor for this target marketing. Should we be asking them for the criteria used to determine who and who is not being targeted for this campaign? or request for reports/date used for the campaign? Finally, what issues/concerns should we have with target marketing of a new deposit product? Again, this is a whole new arena for us, so any thoughts or suggestions are appreciated.

Choose what makes sense for you and the product. We just went through this. You can choose whatever your heart desires in terms of whom to market too.

Thanks for your response. So if we market to "whomever our hearts desire" will examiners view this as a possible "unfair" act or practice under UDAAP?

There are no fair deposit laws. If you were talking about loans, that would be a different story.

So we can target to whomever we want and exclude whomever we want and examiner won't ask us a thing - if this is marketing of a deposit product?

Bumping this. We're in the same boat for a checking product. Entirely new method of marketing for us and I was consulted as the fair lending officer, but we're marketing strictly for a checking product so we can proceed without any concerns as to how we select criteria to drive the prospect list?