Old, Moldy, and Out of Compliance
Got a little free time? Use it to crawl out from behind the grotesque stacks of compliance-related material on your desk and go take a walk into any area of your institution that offers brochures and flyers for customers to pick up. You may be shocked at what you find. We were! It's time for spring cleaning!
We just took a quick stroll through ten financial institution offices. We found:
- A brochure touting a Christmas Club Savings Account that started out with the words "Christmas 2000 will be here before you know it!" Gosh. Don't think so.
- Scads of copies of the lengthy pamphlet from the FDIC titled "Your Insured Deposit" -- the 1993 edition. (Significant changes were made to the deposit insurance coverage rules in 1998 and in 1999.
- A brochure that doubled as a Loan Application that stated on its face that it was to be used for "consumer loans, auto, home equity, real estate, boats & RVs, home improvement and more." The bank is subject to HMDA, yet no monitoring information was requested and there was nothing on the loan app to indicate that it should not be used for certain types of loans (those that would require the institution to request monitoring info).
- Brochures that did not correctly reflect the institution's current requirements for opening deposits, minimum balances, balances to avoid fees, administrative fees for IRA and SEP plans.
- Outdated IRA brochures.
- Brochures featuring the bank's location addresses that continued to list a branch that was sold to (and is now operated by) another financial institution.
- A promotional brochure describing "rewards" the bank no longer even offers to customers.
Who knows what you'll find? From marketing pieces designed to calm customers' Y2K-related jitters to outdated rate data, these moldy materials can hurt your reputation -- and cause compliance problems.
Let us know what you discover. We'll never tell. Well, at least we'll never tell who or where. :-)
First published on BankersOnline.com 5/8/02
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