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Account Closing Survey: CAN-SPAM Rules?

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If our Bank is adopting an account closing survey and they want to send it to closed account customers by text and email, does this fall under the CAN-SPAM rules? They are only requesting feedback, there is no promotional material.

CAN-SPAM rules define a commercial electronic mail message an email (which is NOT what is on a closed loop like messages in an internet banking system), with a primary purpose of promoting a product or service and it is not a transactional or relationship message. Your survey sounds as though it would not fall into these conditions.

I would still omit names of customers who asked not to be contacted, and if it works procedurally, I would try to ask these survey questions when the customer actually closes the account.

First published on 11/17/2019

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