I am a new compliance officer with deposits and advertising being my weakest area. I have a couple of questions related to a new product. Can a bank require that a NOW account is opened based on certain stipulations, such as, email address is a requirement, must accept only e-statements, and must meet a certain number of debit card transactions in order to receive interest? In REG DD; I understand that the customer must consent to receiving statemenets electronically; however, E-Compliance states that the customer must have the option to opt-out at any time, along with other requirements. I'm going head to head with our marketing director who has done nothing but give me a hard time from day one. Marketing is telling me that they know the REGs and that they can offer a product under the terms that a valid email address must always be on file and that the customer must agree to only recieving e-statements for this product.
PLEASE PROVIDE ANY ASSISTANCE YOU CAN!!!!! IT IS GREATLY APPRECIATED.