In response to regulatory agencies mounting concerns on rising credit card debt, many of the nation's credit card companies are increasing minimum monthly payments on card balances.
What disclosures are required on an outside banner for a HELOC with an intro rate?
We would like to gather email addresses from our customers for product solicitations. We would not want to send out personal information, only generic product info. What disclosures and releases would be required from the customer?
"Free Business Checking" is what is being advertised; my question is that, if the disclosure states that customers get 400 free items per month and an excess item fee is $0.18 per item, can this still be advertised as "Free Business Checking"? If "NO," can we denote "Certain restrictions apply"?
I am trying to get a question answered related to HELOCs that have attached credit cards. Are these plans excluded from the requirements under 226.5a? We currently have Home Equity Visa Lines of Credit and are looking to do a direct mail promotion where we have a balance transfer option for a 6 mos period at a lower rate. My question is, can we disclose the different rates for purchases, cash advances, balance transfers, etc., in our HELOC disclosures, or must we have a separate disclosure in a "tabular" format, like we would on our normal direct mail solicitations for a regular credit card product?
We would like to offer an overdraft protection product for our commercial accounts. What compliance issues will be involved? We have a consumer product already with the proper disclosures.
Our bank is getting ready to start imaging loan documents. Where can I get some information about what documents we should keep originals of and not rely on images?
Would the statement "1/4% bonus on CD," listed in a new account advertisement trigger additional APY disclosures?
I am with the trust compliance risk management department and perform compliance reviews for advertising and presentations that frequently involve products from multiple business lines: e.g., a wealth management piece may include reference to private banking, estate and wealth planning, insurance, investment management and brokerage services. How do you handle the multiple regulatory disclosures (FDIC, Equal Housing, Interagency statement, etc.) without completely cluttering the material with disclosure?
We would like to advertise our current HELOC rate on a website banner space that we pay for monthly. When the banner is clicked, it links the person directly to our own website. Here is my question. If we want to put our HELOC rate on the banner ad, can we just say... 4.50% APR fixed* on a HELOC at WSB click here for details Then when they click on it our website would come up with the fine print, details and disclosure information. Is this permissible or does all the "fine print" need to be on the banner with the rate?