Okay, posted in the marketing section with no luck. We are considering target marketing to our Spanish speaking customers and were wondering what others have done to avoid any Reg B issues with regard to how you collect and store the data regarding which customers are Spanish speaking and would be interested in receiving this type of marketing material. I am thinking tight controls on this data would be needed so that it was restricted to only marketing folks and would not be available to lenders or others who could be accused of discriminating by an examiner. How are you guys identifying which customers would benefit from this type of marketing????

Typically, one should employ the same controls for safeguarding information that you apply to all other customers. One key is to ensure that the marketing promotions are not more or less favorable to a particular group or class, especially if it is credit-related.

At a previous bank, we experienced some adverse reaction to some of our hispanic marketing as the individuals targeted did not want to be labeled as spanish-speaking. Be sure to do your due diligence on existing customers that you target any marketing to. For general hispanic marketing initiatives, there are a number of lists one can purchase or online resources that can be found to provide a good pool of potential customers. Also, if the advertising is going to be done through the internet, make the english and spanish versions of the websites as similar as possible to avoid any potential weankesses/issues from an availability and/or product presentation standpoint.

Derek-Thanks for the input. I know we are treading possibly stormy water so want to carefully approach this one.

We have Spanish-speaking Hispanic tellers and CSRs at some of our offices with the highest number of Hispanic customers. Those customers who feel the most comfortable conversing and doing business in Spanish do not do business with anyone else at the bank - it's their choice. We pretty well know who those customers are who would benefit from a targeted marketing push. Talk to your frontline staff - get them to keep a list of customers who seem to prefer dealing with them in Spanish.

How do you guys keep this data handy for marketing campaigns? In a running list in hard copy or do you code something in the CIF somehow after reviewing your data base? I would just prefer to keep this data from anyone but marketing's eyes, but maybe I am being too cautious. You know how compliance and marketing mix so well (like water and oil! )

Our Marketing director created (or had created) a marketing database in Microsoft Access that frontline folk can key in relevant information including keeping track of calls/queries, etc.

I am liking this idea-safe from anyone else in the bank who does not need access to the info, but is readily avaiable to be manipulated into a format that can be easily be incorporated into a mail-merge data base. Thanks for your help!

An Excellent artical titled "Community Bankers Guide to Hispanic Marketing" is in the BOL Info Vault.

www.bankersonline.com/tools/hispanicmarketing2005.pdf

Don-I will forward this to our marketing folks. This is great-thanks.