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#2250065 - 03/03/21 10:38 PM Fair Banking and Deposit Advertising
Tesla Offline
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Joined: Nov 2003
Posts: 3,726
Have any of you started analyzing deposit advertisements for inclusivity? We have a promotion for graduating seniors that only goes to a small portion of our footprint (largely affluent schools and then the public schools right in our neighborhood). I am thinking this is a potential issue, but I don't have a black and white law to hang my hat on like I do for fair lending.

Thoughts?
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#2250066 - 03/03/21 10:42 PM Re: Fair Banking and Deposit Advertising Tesla
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
There are no fair deposit laws. So you are saying this all of the deposit marketing that you do? You always have to take your entire marketing plan in total if you have concerns about reaching your entire market.
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#2250069 - 03/03/21 10:48 PM Re: Fair Banking and Deposit Advertising Tesla
Tesla Offline
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Joined: Nov 2003
Posts: 3,726
Yes. Based on the new rhetoric of "fair and responsible banking" it was my understanding we are to look at all our marketing, for example, to ensure it is inclusive. I agree there is nothing concrete but the vibe you get at conferences and reading speeches from the regulators. An example at an ABA virtual conference was if you promoted a checking product with a minimum opening balance of $1,000 and you had no other checking accounts available, you are excluding groups of people who would not be able to open an account with $1,000.

In this case, we are giving promotional items and a bonus incentive to students from certain schools but not all schools in our assessment area.
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#2250072 - 03/04/21 12:50 AM Re: Fair Banking and Deposit Advertising Tesla
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
we are to look at all our marketing,

Yes, that was my point. You do not go to fair lending jail for one marketing campaign. You have to look at marketing in total.

Giving promotional items and bonus incentives to a very limited audience however does cloud the issue, which you did not mention in your original e-mail.
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#2250077 - 03/04/21 02:39 PM Re: Fair Banking and Deposit Advertising Tesla
Tesla Offline
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Joined: Nov 2003
Posts: 3,726
Thanks Randy. I wasn't trying to be deceptive in my question, but trying to be a little vague so my bank would not know I was questioning this as they have literally done this for over 50 years.

My approach is to expand this promotion next year as it is too late to do so now.

Thank you for your assistance. It always help to "talk" it out with someone. smile
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