Revamping Deposit Account Brochures

Posted By: complygirl

Revamping Deposit Account Brochures - 06/23/16 08:32 PM

We have brochures that summarize the terms of each account type we offer...one brochure for personal checking accounts offered by the bank, one for savings, one for business checking, etc. that we are making major revisions to. We want to be sure all requirements are being met. These would be provided when a customer is inquiring or shopping for a new deposit account and does not take the place of our TISA disclosures. Where can I find the regulatory requirement outlining what would be required to be included in this type of document? It is a promotional/advertising type document, but does list the basic account terms (however specific rates, etc. are not included).
Posted By: John Burnett

Re: Revamping Deposit Account Brochures - 06/24/16 03:59 PM

You subject them to two tests.

First, they fit the definition of an advertisement. Make sure that you include "Member FDIC." Also check to see if you have included anything that qualifies as a "trigger" in section 1030.8 of Regulation DD to require additional information.

Second, read them through carefully to ensure they are accurate and not in any way misleading as to the features of the account, etc. It often helps to have a non-banker do this and ask questions about what he or she has read.