Does anyone have experience with offering additional services when a customer calls into your call center? For instance, the FI is running a balance transfer offer to all existing cardholders. The rep would see they have credit available for use as a balance transfer and ask the customer if they would be interest in paying off a higher APR debt. If the customer is interested, the rep could do the transfer for them. Would it require a notice to the customer or is the fact that it posts to their credi card account and they see it on their statement enough? We're struggling with what is the proper way to handle this and Reg Z doesn't address it.

Are there additional charge fees for these transfers? How does the call center "do the transfer for them"? These are not loans with your bank - correct? If they are: 1) why would you encourage them to pay down loans with a higher APR and 2) if these other loans are secured loans, why would you replace secured debt with unsecured debt?

This would be a third-party vendor support center answering customer credit card inquiries. If a promotion was going on, they would tell customers about it and see if they had any other balances they would like to transfer. It would be a valid offer available to all existing cardholders. Most likely there would not be a fee. The rep could go into the system and input the balance transfer information for the customer. The customer would not receive a confirmation, but they would see it on their monthly statement. Is this acceptable? If not, what are the obstacles?

This is off-topic but I just want to mention that I participated in a promotion of exactly this sort. I had contact with over 900 customers - personally - and exactly zero of them accepted the offer.

So if you are in a position to have any influence on the decision of whether to even offer or launch this campaign, I'd consider doing some testing. Try it for a day, and if you get zero nibbles, stop bothering your questions with what many customers will think is an invasive and irritating line of questioning. For instance, consider the info you don't have here. You're saying that if you see that the customer has a balance available to spend at your bank, then you would offer them the ability to transfer (a totally imaginary) higher APR balance from some other card. So you're fishing in the dark there, having no idea if they even have any other credit cards or if those cards have a balance. This approach fails the most basic tenets of salesmanship, as far as identifying a need before offering a service.

So, if you're stuck with that limitation, then unless you have a significant incentive to offer - like "Get a $50 statement credit if you accept this fabulous balance transfer offer," I think you're wasting your time. [I don't know if such an offer would even be legal, by the way - I'm just saying unless there is something obvious the customer will "get" for listening to your pitch, their answer is likely to be, "No, no, shut up, I just called to get my checking balance."]

It is strictly a call center for the credit card. I understand this is what they do with all of their customer calls. They're trained to look for an upsell. Thank you for your input, but I really am looking for more guidance on disclosure compliance. Something specifically touched on in the regulation.

If balance transfer charges were initially disclosed or there are no special charges, then I am confused as to what you are asking. If they were not, then you need to send a change of terms to all of your card holders. Or, I am severely missing your question.

Everything has been disclosed properly, even the balance transfer promotion without a fee. If a customer hasn't taken advantage of the offer and they just happen to call the credit card call center for say a question on their statement, the representative might ask them if they had any other balances on other banks cards to pay down or pay off by using a balance transfer. My question is, do they need to provide anything as proof of the transfer or will the fact that it posts to their statement be enough? I don't know how else to explain it. I'm trying to associate this with a regulation but can't find any reference to phone calls in Reg Z. It's not really a solicitation because the customer called the bank and the suggestion is put out there to them during the call.