Our marketing department wants to offer $20 for any customer who opens a new Bill Pay account and makes one payment online to receive the bonus. Does this fall under a lottery? Is this okay?
What is the regulatory requirement for declining a customer the Bill Pay Service?
IMPORTANT NOTE: Effective July 2, 2009, the separate treatment of third party payments by check, debit card, draft or other similar payment orders is ended by an amendment to § 204.2(d)(2) o
Marketing is sending out a pretty generic letter to potential customers in an area where a branch of another bank has closed. The list of potential customers came from an employee from that area. The letter includes a no fee checking product and lists the features; unlimited check writing, no minimum balance requirement, and no monthly fees, with a sentence that we offer commercial and agricultural loans, free online banking, bill pay and safe deposit boxes. This will be on bank letter head. Do we need Member FDIC and Equal Housing Lender? What about the "no fees" and "free"?
Would checks issued by third-party online bill payment service providers be consider "official checks" under Reg CC for the purpose of assigning float? We have such a check that we assigned our non-local 2-day float to because even though the financial institution is local, the issuer (third-party bill payer) is not. The routing number on the check is non-local for us. Our customer is wondering why we didn't provide next-day availability because the words "Official Check" appeared on the item. I would say that this check does not meet the definition of either a cashier's or teller check. Am I correct?
We are thinking about offering a premium with the retail value of $49 when you open a new personal checking account and sign up for a debit card or online bill payment. The premium gift would only be paid upon first use of the debit card or online bill pay. Because the premium is being paid for activity on a debit card or online bill pay account and not for the opening of the checking account itself, does the $10/$20 demand deposit bonus rule still apply?
We are thinking about doing a promotion on our Free Bill Pay. We had thought about doing a give away to our customers and the way to enter would be to use the bill pay. For each bill that is paid, their name would be entered into the drawing. Is this a violation of any laws or regulations? Internet Banking and Bill Pay are free products offered to all customers.
HSBC Bank USA, New York, has launched an aggressive marketing campaign for "selling" its free checking account.
A new survey by InsightExpress found that the number of U.S. online consumers using the Internet to pay bills has increased from 17 percent in 2000 to 57 percent in 2003.
Two studies recently revealed that consumers are becoming more comfortable with electronic bill payment but the percentages are still relatively small.