07/30/2007
If we advertise a deposit rate on our website and include a "click here" link for the required Reg DD disclosures, would this be permissible? Or is it an absolute requirement to have the required disclosures appear alongside the rate?
07/16/2007
A third party auditor noted an exception for not including the NOT FDIC, etc. language on an ad that was in the name of our affilate insurance company. The bank's name wasn't mentioned anywhere. I don't think this is required, but am not finding a helpful resource. If we had mentioned the Bank's name also then yes...anyone?
06/25/2007
We are designing a brochure for our gift card program. We work with a vendor on this program; the vendor receives part of the fee for a card purchased and the bank receives the remainder. We sell these cards to both customers and non-customers. A gift card does not fit the definition of an "account" under TISA. Would we have to disclose the fees on the brochure? Could we say "ask about the fees" or do we have to disclose the fee schedule? Or could we be silent on the fees? Or is this a deceptive advertising practice? I am also reviewing the contract with the vendor to see if the vendor requires us to disclose fees when advertising.
06/11/2007
We are an insurance agency offering discounts to customers of a bank. The discounts apply to property and casualty insurance. Do we need to include "not FDIC insured" on our marketing materials? If so, what is the proper verbiage? Our marketing materials include the bank's name and logo.
05/28/2007
We are designing a brochure for our Gift card program. We work with a vendor on this program; the vendor receives part of the fee for a card purchased and the bank receives the remainder. We sell these cards to both customers and non-customers. A gift card does not fit the definition of an "account" under TISA. Would we have to disclose the fees on the brochure? Could we say "ask about the fees" or do we have to disclose the fee schedule? Or could we be silent on the fees? Or is this a deceptive advertising practice? I am also reviewing the contract with the vendor to see if the vendor requires us to disclose fees when advertising.
05/21/2007
When reviewing our website, what are the main compliance issues we need to look for?
05/21/2007
Do we need to give everyone who opens an account with us a Check 21 disclosure or do we give them only to customers that get checks returned with their statements?
05/14/2007
I am updating the bank's signature card sample and I am starting to question myself about ownership and disclosures for fiduciary accounts. For example, we open an escrow account for a realtor with the account titled "John Doe, Escrow Account" and the realtor is the authorized signer. Is this a personal purpose or business purpose and what disclosures do you give them? Are fiduciary accounts personal or business if the funds are held for a individual?
05/07/2007
During a recent FDIC audit, we were told that returned deposit notices involving checks that had been converted into IRD's needed a Check 21 disclosure notice enclosed with the notification/check. Our account opening disclosures already have the Check 21 disclosures included with them. Is this correct or were they mistaken?
04/30/2007
We want to change our procedures for opening accounts to include asking for an email address, with the purpose being for email alerts and ads. I cannot find where this would not be allowed as long as we have the unsubscribe feature. Is this correct?