Answer:
There are a couple of points one should consider when cross selling products and services. You need to remember that when loans are being sold and rates are quoted, annual percentage rates should be used. Credit reports accessed for one purpose should not be used for another, such as cross selling. Refer to the Gowen letter ruling by the FTC. Non-deposit investment products enter a gray area when discussed in an area where insured products are discussed.
What I would recommend is a procedure for cross selling. Write out scripts or talk-offs that your staff can use to sell other products and services. This allows you to standardize what is said and to include and exclude what you want. Marketing and compliance can both tweak the text to both sell and remain compliant. The use of scripts will help you avoid (if desired) triggering terms under Reg Z and Reg DD when discussing loan terms or deposit products and overdrafts. It will allow you to use representative samples for actual products and the math can be done already when rates are discussed. Once your customer is interested the staffer would know to whom to refer this customer.
First published on BankersOnline.com 11/17/08
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