Is the bank required to disclose that a bonus paid will be considered interest and be reported on a 1099-Misc? Should the information be
disclosed in the advertisement of a bonus?
We are advertising a $125 bonus that will be paid when a customer completes a few requirements, including opening 1 of 3 various non-interest and
interest-bearing checking accounts, signing up for a direct deposit, and using our mobile banking app. I wasn't planning to disclose an interest
rate or APY to avoid the additional disclosures caused by the trigger term. However, when disclosing a bonus, the APY appears to be a requirement. I wanted to verify that we have to disclose the APY (using the term annual percentage yield) and the additional disclosures caused by this trigger term
if we are disclosing a bonus. Or, does the APY disclosure requirement for a bonus not apply if we were not planning to disclose the interest rate or
APY? Also, are we required to use the word "bonus" in our ad?
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?
Do weblinking rules apply if a business has a link to us, and are we required to monitor this?
What is the “one-click away” rule for electronic advertisements?
If credit is denied because of issues related to only one applicant, for example a charge-off, can we disclose that reason to both applicants, and do both applicants get an Adverse Action Notice?
We have a vendor who will be conducting a telephone survey pertaining to our customers' experience and usage with our credit card product. The following is our process:
1) Customers listing is obtained from the banks payment processor.
2) Customers who "Opted Out" will be excluded.
3) Our vendor conducting the survey will ensure the customer has the opportunity at the beginning of the call to decline taking the survey as a courtesy.
4) Customers called are not randomly selected but based on our customer listing.
Has there been a case where a lender tried so hard to assist minority applicants that it had a fair lending issue with majority applicants?
Our lender had a request for a reverse mortgage. He provided an Adverse Action Notice, but did he have to, since we don’t offer reverse mortgage loans?