I've just received a credit card marketing campaign to review that will be directed to our customers ages 18-25. In the past we've avoided any age limits (except provided the applicant has the capacity to contract) in our advertising. Since all of our other advertising, including online advertising, is not limited, is there a problem doing a campaign to this age group only. Or must we have similar campaigns to other age groups as well to "even our the advertising" and show our efforts not to exclude anyone from our advertising overall?

Any advice or regulation references I should be considering?

Thanks in advance.

I assume it is not a special credit card product - correct? Everyone gets the same thing regardless of age? Targeting only specific audiences always has its risks

Not a special credit card product; yes everyone gets the same thing. If marketing develops a plan for various campaigns to reach all ages, do you think this will help reduce that risk?

That would definitely be a step in the right direction.

LTC, just some additional steps.
Review your regulator's Fair Lending Examination Procedures for Marketing and Redlining. Make sure that you have documented, to defend the types of advertising/marketing the bank does. The procedures will tell you what they look at so just document it ahead of time so when the regulators show up and ask, they know that you had considered everything rather than having it right purely by chance. Added kudos for the management perspective.

Don't forget the special rules for young consumers (under 21 years old) in section 1026.51(b) of Reg Z.