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#34092 - 09/23/02 07:52 PM Reg DD
Peepers Offline
10K Club
Joined: Jul 2002
Posts: 13,994
We want to pay consumers up to $10 for their unused checks if they open a checking account with us.

I know to stay under the $10 to avoid triggering bonus disclosures.

However, our marketing department wants to limit this offer to our newest branch.

My question, is there any discrimination law to look at because this won't be offered at every branch?

I just want to cover all my bases. ECOA doesn't come into play here, but I'm wondering if something else does on the deposit side.

And while I'm at it, I'll pose one more situation. As part of the one year anniversary of this branch, we want to offer cash prizes in a random drawing, $150, $100 and $50. These aren't tied to offering, opening, renewing or increasing an account so I'm thinking we're ok here with no additional disclosure requirements.
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#34093 - 09/23/02 07:59 PM Re: Reg DD
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,378
On the Net
Some folks will ask where the newest branch is and if that has a disparate impact. Personally I believe that if you are doing this because it is an individual branch promotion to boost new accounts, you are fine.

And if the drawing is open to anyone who registers, and registration doesn't depend on my opening an account or paying any fee, directly or indirectly, it should be OK as well, unless you have some state law about drawings.
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#34094 - 09/23/02 08:06 PM Re: Reg DD
Tina A Sweet Offline
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Tina A Sweet
Joined: Aug 2001
Posts: 1,033
Marysville, Ca.
Andy has hit the target again.
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#34095 - 09/23/02 08:21 PM Re: Reg DD
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I agree with Andy's comments but wanted to specifically address tmf's questions. There are no "fair deposit" regulations. If you discriminate on the deposit side, you will not have broken any regulations. However, it may not be a good business practice.
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#34096 - 09/23/02 08:52 PM Re: Reg DD
I Wear Many Hats Offline
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I Wear Many Hats
Joined: Mar 2001
Posts: 591
the beautiful state of ME
The only caveat that we use when we do a special promotion like that in one branch is that if a customer goes into another branch and asks for the offer (heard about it from Uncle Joe or whatever), we give them the deal as well - our goal is to attract new business to the newer branch but we don't want to alienate in other towns. With regard to the drawing, we always advertise "no purchase necessary" just so people will know ....

Opinions are mine and mine alone.
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#34097 - 09/24/02 02:44 PM Re: Reg DD
Peepers Offline
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Joined: Jul 2002
Posts: 13,994
Thank you Andy, Tina, David and Sue. As always, I appreciate everyone's input.
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