Hi,

Every year my bank gives a free gift to graduating seniors of the local high schools, which is given by the school on graduation day. This year we missed the deadline for the graduation, so I am suggesting the bank run its regular "Congratulations Seniors" ad with a line that says visit our local branch to receive your free gift. I don't see any compliance issues with this, but wanted to be sure before running the ad. The gift is free, but it is only for graduating seniors of a few local schools - any problems with this idea?

Thanks!

If the gift is available to anyone regardless of customer or not, you should not have any concerns. It would be the same as handing out rulers at a trade show. The only compliance issue would be to put Member FDIC in the ad.

Would you mind to share what you are giving the seniors? This is a neat idea!

Original Poster here - forgot to login!

The gift is a "mini diploma" - a wallet sized replica of their diploma laminated. You give the company a blank, signed diploma from the school and they type in the names from a list you give them. The diploma is on one side, and on the reverse side there is a "Congratulations from ________ Bank! with the bank's logo, name, number and address. (Similar to a business card). Most of the seniors love them! I work with someone who still has his from 20 years ago! They run about $3 a piece without the gift envelopes - we usually give them to the school and they hand them out with their actual diploma.

If anyone would like the contact info for the company we use, please pm me and I will e-mail it to you as I don't know if I can "promote" a business on the forums. It is probably too late for this year, but maybe you can put it aside for next year

Why would there be a problem with putting "Member FDIC" in the ad? We've taken the stance at our bank that anytime our name is used, except with non-bank products such as insurance, investments, trust, etc, that we put that in there. Several seminars that I've gone to have even said that just by using the name of your bank in the ad implies that you accept deposits and you should use the Member FDIC. So why would using it here be an issue?

I would take the position that the diploma is like a pen or pencil and that putting member fdic is impratical and take my chances with the regulators criticizing me for this.

Wouldn't you then have to add FDIC to every ad including credit cards? I thought FDIC was only needed if you were specifically marketing a deposit account?

Aleta Jo