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#2246745 - 12/18/20 07:55 PM Social media post for digital wallet
Helpcompliance Offline
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Joined: Mar 2015
Posts: 31
Kentucky
What compliance requirements need to be included in a social media post promoting the digital wallet?

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Marketing
#2246749 - 12/18/20 09:25 PM Re: Social media post for digital wallet Helpcompliance
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,584
Galveston, TX
You know, I'm pretty old school so I am not sure what the exact definition of a "digital wallet" might be. Is it even officially defined anywhere? I have never seen that term referenced in a regulation. So, without knowing the actual context of the advertisement, it is hard to say. It might be like saying "what compliance requirements need to be included in an advertisement of a loan" - without further explanation.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2246809 - 12/22/20 03:40 AM Re: Social media post for digital wallet Helpcompliance
Helpcompliance Offline
Junior Member
Joined: Mar 2015
Posts: 31
Kentucky
I have not seen the definition of “digital wallet” in the regulations. That is why I am asking because I am not sure where to look concerning requirements for social media posts. The bank recently allowed debit cards to be added to digital wallet apps like the iPhone’s wallet (and other devices). These apps allow customers to pay for purchases with debit cards by using the cell phone app. The bank’s marketing area wants to promote this service on social media, so I am trying to determine what needs to be listed in the post. I know the Member FDIC needs to be included, but I am trying to decide what else would be required. Any guidance offered would be much appreciated.

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#2246813 - 12/22/20 02:02 PM Re: Social media post for digital wallet Helpcompliance
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,584
Galveston, TX
So the bank wants to promote someone else's services? I hope they also fully inform the consumer that once they sign up for such a service, if their device is lost or hacked, that the Regulation E protections offered by the bank will no longer apply and they will have to deal with whatever customer service and protections the "digital wallet" provider is prepared to offer.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2246832 - 12/22/20 05:24 PM Re: Social media post for digital wallet rlcarey
Helpcompliance Offline
Junior Member
Joined: Mar 2015
Posts: 31
Kentucky
The terms and conditions (agreement) that the customer must agree to before using the service covers all the information mentioned, including the loss of Regulation E coverage. The agreement informs the user to refer to the “digital wallet” provider concerning protection. Including language that relates to the terms and conditions of usage in the post is a great idea. Thank you.

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