Answer:
Answer by Rick Wemmers:
Yes, if you can provide something the ad production provider needs.
Answer:
Answer by Mary Beth Guard:
From a compliance standpoint, I'd want to know what the bank is going to be offering and to whom, to make sure you aren't going to run afoul of any laws or regs.
Is the party with whom you'll be bartering an insider under Reg O? Are they are an affiliate under 23A? Are they someone who wears multiple hats and is perhaps also a provider of some type of settlement services under RESPA?
The examiners will look at who gave what to whom -- and why. If there are mixed motives and questionable exchanges of value, watch out! You don't want to do anything that would smell like a Bank Bribery Act violation, an illegal kickback under RESPA or any other type of violation.
First published on BankersOnline.com 2/4/02
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