Latest Lending - Advertising Topics

Credit Card Promotion-Waive Annual Fee

07/05/2020

The bank is considering a credit card promotion for a period of 90 days that will waive the annual fee for the life of the credit card. A customer must apply for the credit card during this time frame to be eligible. It will not be advertised externally. Must the credit card application be altered or can we leave the annual fee on the app in case other customers take the application with them? What other compliance requirements exist for this type of promotion?

AAN? We don’t make those loans.

06/21/2020

During the PPP loan programs we had many requests, but we were not participating? These are commercial requests and would be subject to Reg B. Were adverse action notices required?

UDAAP penalties can be costly

05/17/2020

How much "teeth" does UDAAP really have to penalize a bank?

Tweets that haunt

03/08/2020

Since some employees have used social media for years without a problem, I guess I don’t understand why there is concern now about risks. What risks are there?

Rate Sheets and CAN-SPAM

03/01/2020

Are rate sheets we send to auto dealers and mortgage brokers CAN-SPAM covered?

Hang ups and Do Not Call lists: When Must a Consumer be Removed?

02/23/2020

Many times when I get a call I start to say “remove this number from your call list” but the caller hangs up before I’m done. Is this illegal since they didn’t provide time to get this request? If so, we should train our calling staff to listen for this and proceed as you mentioned, to remove the number, correct?

Mortgage Lenders Only

02/23/2020

We are just a mortgage lender, does this CAN-SPAM affect us?

Equal Housing Lender Logo on Business Card?

12/08/2019

Does a mortgage lender's business card require an Equal Housing Lender logo?

Home Equity Rate Special Disclosure Details

12/08/2019

Can we remove some of the details in a home equity rate special disclosure for billboard advertising and replace with a toll free number?

UDAAP penalties can be costly

11/10/2019

How much "teeth" does UDAAP really have to penalize a bank?