We're preparing to roll out instant-issue cards, and management has decided they're only going to offer it to one BIN # for now. That # excludes anyone in our "young adult" type program that's 16-22 (stupid, terrible, and pointless program, but supposed to have more focus on personal finance education, etc).

Since it's not related to lending, would it be anything other than UDAAP to think about? They're considering it fraud protection along with just being easier/cheaper to roll out, since we don't have to launch multiple BINs. Not disagreeing with that logic, but I think there are other ways to mitigate the risk than just pinpointing kids as the problem.

Multiple BINs? How would this create multiple Bins??

If I understand the question, it sounds like the bank already has multiple BINs but they only want to roll out their instant issue debit card program to one BIN that does not include this 16-22 year old group.

Since there are no fair deposit laws, and you are continuing to offer debit cards to these customers, just not of the instant issue variety, I don't see an issue here.

Correct understanding Brian, yes.

Sounds good, thanks. I think it's going to backfire, as the product will likely be of far more interest to the younger demographic, but I'm in Compliance, not Marketing or Operations, so that's not my problem