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#26002 - 07/30/02 09:07 PM Checking acct. Advertising

We offer an "overdraft priviledge" of $300 to customers in which we will pay checks and cover an overdraft up to $300. The customer still has to pay the bank an overdraft fee. On our written disclosure it explains that the overdraft fee is still paid and that payment of an overdraft does not obligate the bank to pay future overdrafts....My question is for radio advertisements if we mention overdraft priviledges up to $300 do we have to have the entire disclosure read with the ad?

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General Discussion
#26003 - 07/30/02 09:15 PM Re: Checking acct. Advertising
Andy_Z Offline
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Joined: Oct 2000
Posts: 27,503
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When I have heard similar ads, there is usually a disclaimer that certain conditions and restrictions apply. The other caveat you could add in would be "to apply", assuming you have some process in place doing this.

In short, I'd be careful so that it doesn't appear to be a line of credit, I'd ensure there is no bait and switch product, but I don't believe the entire program has to be laid out in a radio ad.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#26004 - 07/30/02 09:19 PM Re: Checking acct. Advertising
SJB Offline
Diamond Poster
Joined: Jun 2002
Posts: 1,210
See 12 CFR 230.8. Assuming you are not advertising the APY or a bonus you don't have any trigger terms so I think your disclosure can be pretty simple, "Overdraft fees may apply, member FDIC." (Don't even need the FDIC bit if 30 seconds or less.)
My opinions are not legal advice and are worth what you paid for them.

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