What is your opinion of offering a checking account that offers add-on third party benefits as a feature of the account? Customers are only able to obtain the add-on services if they buy the account and pay the service charge disclosed for this product.
Does UDAAP apply to just consumers, or all customers?
Can we advertise a drawing on social media only?
We had a problem with debit card claims so we modified our deposit agreement. If they don’t cooperate in the claim process, we can deny it. Problem solved!
Our local Chamber of Commerce is giving away raffle tickets for a chance to win a shopping spree downtown for the holidays. They have asked the bank to offer tickets to our customers. My question is, may we offer multiple tickets to customers if they were to sign up for certain services? For example: Make a deposit worth 1 ticket, sign up for online banking and receive 2. Another example would be to apply for a car loan and receive 1 ticket, qualify and finance with us pays 5 tickets.
What is the “one-click away” rule for electronic advertisements?
We are rolling out a new rewards program. For members who maintain multiple accounts with direct deposit and have an average balance of at least $XX,XXX, we’re going to rebate X% of each debit card purchase, up to $100 per year.
I was reading some compliance discussions that noted if the credit/rebate is tied to a service instead of just opening and maintaining an account, then it would not be considered a bonus or need to be reported on a 1099-INT. In this case, the accountholder would first need to qualify for a certain level on our rewards program based on their products and balance. However, to receive the rebate, they would need to use their debit card to receive the rebate reward up to $50.
We are leaning towards the rebates not being a bonus or reported on a 1099-INT as payment is triggered on the use of their debit card, not solely on opening or maintaining an account. Thoughts?
My question pertains to customer notices and brochures. I thought that if a bank posts one notice or brochure in another language it must post all notices and brochures in that language. In other words, if we do one sign in a second language (say Spanish), do we need to post all signs and/or brochures in Spanish?
Have the agencies taken any action against influencers?
What are current CFPB Regulatory Initiatives?