We are currently offering two promotional products invovling high minimum deposits. In order to promote the products, we are considering a direct mail campaign targeting a certain household income within certain zip codes to ensure our marketing dollars do not go to waste. I think we may have an issue with that and am looking for further guidance.

There are no "fair deposit" regulations.

Are there lending advertisements in this mailer?

The mail piece would only contain information regarding deposit accounts with the special rates - all information stated would of course comply with guidelines associated with having the stated APY.

Even if the targetted promo piece does not mention credit, there's an indirect fair lending risk.

Almost all banks favor depositors over non-depositors when granting credit and pricing credit products. The goal of the promotion under consideration is to increase the number and percentage of wealthy depositors. Other residents within your service area will not get this opportunity to become a depositor. In effect, you are redlining them.

Later, when these individuals show up as loan applicants, they are treated less favorably than those who reside in high-wealth neighborhoods to which you have targetted your promotions.

But, if this is just one piece of your overall marketing plan, I would not be losing too much sleep over it.

I've seen this work VERY WELL for CD's....good idea...good luck.