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#994993 - 07/14/08 09:24 PM e-mail marketing
RBanker Offline
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Austin Texas
Ok, Our marketing partner is wanting us to provide e-mail addreses of our customers to do direct marketing. I maintain these are gathered at account opening, and thus are non-public/confidential information -
We're a new bank, so the push is on to increase deposits, but I don't want a wrong shortcut. Any idea on where I can find commentary to support e-mail addresses being confidential information?
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Marketing
#995027 - 07/14/08 10:03 PM Re: e-mail marketing RBanker
Richard Insley Offline
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Toano, VA
What's being marketed--your products or something else?
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#995037 - 07/14/08 10:21 PM Re: e-mail marketing Richard Insley
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Austin Texas
Products - Services
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#995097 - 07/15/08 12:32 AM Re: e-mail marketing RBanker
Richard Insley Offline
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Richard Insley
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Toano, VA
You're certainly free to use customer EMAs for promotion of your bank's products and services. Read up on the CAN-SPAM Act in order to know your responsibilities for email promos.
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#995187 - 07/15/08 01:19 PM Re: e-mail marketing Richard Insley
RBanker Offline
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Austin Texas
Great - thanks for pointing me in the right direction.
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#997687 - 07/17/08 01:41 PM Re: e-mail marketing RBanker
RBanker Offline
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Austin Texas
Thanks for the reference - I've been to the FTC site and reviewed that information - which seems pretty straight forward - my concern is really more about sharing customer's e-mail addresses with our marketing firm - do I have a potential issue there? Is is this an example of an affiliated third party?
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#1011531 - 08/04/08 04:19 PM Re: e-mail marketing RBanker
Andy_Z Offline
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From a Reg P document from the FRB 06-02.

Section 216.13 allows you to disclose a consumer’s nonpublic personal information to a nonaffiliated third party who performs services for you or functions on your behalf without providing the consumer an opt-out notice. However, to qualify for this exception, you must (1) enter into a contractual agreement prohibiting the third-party recipient from disclosing or using the nonpublic personal information other than to carry out the purpose(s) for which you disclose the information and (2) provide an initial notice to the consumer, whether or not he or she is your customer, that includes a separate statement describing the categories of information you disclose and the parties with whom you have contracted. §§ 216.6(a)(5) and 216.13(a)(1). If you satisfy these requirements, you could, for example, enter an arrangement under which you disclose nonpublic personal information to a nonaffiliated third party that markets your own financial products and services, such as a telemarketer or direct mail marketer.
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