Complaints and UDAAP – The Risk is Real

Answered by:

Question:

What is your opinion of offering a checking account that offers add-on third party benefits as a feature of the account? Customers are only able to obtain the add-on services if they buy the account and pay the service charge disclosed for this product.

Answer:

If certain features are footnoted such as by an asterisk “*” which then clearly states, “These services are provided only with the Super Saver account” and the Super Saver account clearly discloses it has a cost, you should be fine. But you must view the entirety of the ad. Are the footnotes clear and conspicuous, and are any important points buried in mouse print or separated from the ad so it appears detached from this product? Ask yourself if the reader will understand the attributes of the product? If not, revise it.
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UDAAP, the Risk is Real