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Marketing Club Account to Young Professionals

Our bank is considering a "club account" marketed towards young professionals. I know on the lending side we have ECOA and fair lending to take into consideration, what areas of potential discrimination should we consider on the deposit side? I have read the question answered by Andy Zavoina entitled Is Free Checking for 50 and older an ECOA violation? Are there other regulatory areas to take into consideration?

If you are talking strictly about deposit account products, there are no implications. There are (at this time anyway) no fair deposit regulations. The only caveat is that you can't offer preferential deposit rates to insiders. If your deposit account offering crosses the line into the credit world, i.e., overdraft protection, etc., then you have to carefully assess the situation in regard to fair lending concerns.

First published on 8/01/05

First published on 08/01/2005

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