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#78402 - 05/06/03 04:01 PM
Yet Another WHAT IF...
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New Poster
Joined: Feb 2002
Posts: 23
Lincoln, NE
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What if your looking through this past Sunday's paper, and see an Ad that promotes your bank ATM and another business at a local mall. The bank logo with letters ATM above it, doesn't say "Member FDIC".
Come to find out, the Marketing department didn't do the Ad, (nor did the complianc officer review-me) it was done by the other business/mall. Is the bank in violation for failing to include the "Member FDIC"?
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May all your rides have a tailwind, no matter which way you go.
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#78403 - 05/06/03 04:24 PM
Re: Yet Another WHAT IF...
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10K Club
Joined: Oct 2000
Posts: 27,769
On the Net
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You can't control that until after the fact. When someone wants to review your marketing materials, that won't be there.
It is advisable to contact them and ask that they not do this again, however.
You also might have an exclusion under 328.3, (Exclusions)(7) Joint or group advertisements of banking services where the names of insured banks and noninsured banks or institutions are listed and form a part of such advertisements;
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AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#78404 - 05/06/03 04:25 PM
Re: Yet Another WHAT IF...
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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Just a gentle reminder, if your post has a descriptive heading you are more likely to get a respondent who has an interest in and knowledge regarding the subject matter.
Andy's just naturally curious.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#78405 - 05/06/03 04:28 PM
Re: Yet Another WHAT IF...
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10K Club
Joined: Oct 2000
Posts: 27,769
On the Net
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Ken, are you asking, "what if" I wasn't curious? Perhaps I wouldn't have looked.  Good point. It also helps on searches later.
_________________________
AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#78406 - 05/06/03 04:40 PM
Re: Yet Another WHAT IF...
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Power Poster
Joined: Nov 2001
Posts: 6,719
PA
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Quote:
Andy's just naturally curious.
And naturally knowledgeable!
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#78407 - 05/06/03 06:35 PM
Re: Yet Another WHAT IF...
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Platinum Poster
Joined: Nov 2002
Posts: 598
Flushing, NY
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Heard this on the radio this morning -- one bank ad ended with "Member FDIC -- as if you didn't know"!
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It really doesn't matter, no one listens to me anyway.
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#78408 - 05/06/03 07:55 PM
Re: Yet Another WHAT IF...
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Diamond Poster
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
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When I think of soliciting deposits, I think "new accounts". I doubt if someone can open a new account at your ATM. For that matter, can they even make a deposit?
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Al Miller, CRCM Opinions expressed are my own and not necessarily shared by my employer.
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#78409 - 05/06/03 08:37 PM
Re: Yet Another WHAT IF...
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New Poster
Joined: Feb 2002
Posts: 23
Lincoln, NE
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Call me Mr. Conservative, but your right, they can't even make a deposit at this ATM.
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May all your rides have a tailwind, no matter which way you go.
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#78410 - 05/06/03 09:13 PM
Re: Yet Another WHAT IF...
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Joined: Oct 2000
Posts: 27,769
On the Net
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I would still caution them about using the bank in its advertisement. Who knows what they'll put next time? While free advertising doesn't sound bad, do you want any Tom, Dick and Harry co-branding themselves with your good name.
_________________________
AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#78411 - 05/07/03 11:12 PM
Re: Yet Another WHAT IF...
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Power Poster
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
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I'd have the stern talk about the advertising. I had to do so with an agency that advertised "for us" in the small business line. They had no experience with small business lending so using our name (the largest small business lender in the state) made them sound really spiffy. Unfortunately we had a mortgage relationship with them and I didn't appreciate the tie in.
If it's in writing, folks believe it. It's best to keep a handle on who and where your name is used. (although mine is always allowed when the subject of wine is mentioned)
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Dawn Coursey VP/CRA Queen
CRA Rating is in...Oh who cares...I'm home with the baby.
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