Well, your advertising is going to have to be very specific - that is probably your biggest risk for a UDAP.
Like what do you mean bring their deposit accounts to the bank? Just open an account, open a checking account, savings account, both, transfer balances of $$$, how long do they have to remain open, what if they keep $5 in the account, what if they close them the day after the loan closes? All questions like these need to be answered and then applied equitably across the board.
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