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Reg DD - Marketing of New Accounts

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Question: 
In general how will the recent changes to Reg DD affect our marketing of new accounts?
Answer: 

The definition of advertisement has expanded to encompass actions that you don't think of as advertising. For example, the simple act of providing a balance that includes an ODP cushion is advertising that promotes the payment of overdrafts per the regulation, and triggers both advertising and statement augmentation.

With regard to ads for free accounts, you'll want to make very sure you don't include any references to services for which there might be a fee, such as bill payment or ODP, unless you indicate in the ad that there is a fee for that service. If the service is ODP, there are four specific disclosures you'll have to include, as detailed in section 230.11(b).

First published on BankersOnline.com 7/17/06

First published on 07/17/2006

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