07/26/2010
We have a couple of tech-savvy lending officers who regularly post to personal blogs. We have a policy requirement that their blogging must include disclaimers that they are expressing personal opinions only and not writing on behalf of the bank.However, occasionally they may mention a bank product or service ("My bank offers a 35-year fixed rate loan" appeared in one of the blogs last week). Can their blogs be considered advertisements with trigger terms and compliance issues for the bank? Do we have to control what they post?
04/19/2010
Does the Fair Lending Act limit the ability of a bank to use age as a targeting tool in direct marketing for loans?
12/14/2009
Marketing is working on our E-SIGN promotions and wants to know what the E-SIGN agreement will include. Is it just lending, deposits, or can it include both?
10/26/2009
At a grand opening or moving project, we would like to use a prize wheel. The prize wheel would only have items that range in value from $1.00 to $25.00. The $25 items obviously being the single panel on the wheel. If anyone who spins the wheel is guaranteed some specialty object or prize, can we use it at an event? In other words, there would be no “Lose Turn” or “Bankrupt” as seen on TV. Prize wheel gifts will be changed on a regular basis. And, in order to be able to spin the wheel you have to bring in the direct mail piece. No account existing or new account is necessary in order to participate. Is this a problem?
07/20/2009
One of our board members wants to send a congratulating letter and a lending brochure to newly married couples that appear in the paper. Are there any issues with this marketing idea?
03/16/2009
My marketing department is planning on sending e-mails containing lending advertisements for selected brokers. I received one for review and it contained commercial loan information such as rate, terms and a picture of the location. I know Reg Z doesn't cover advertising for this as long as we have the EH logo, but what about privacy issues? Are we still required to send an authorization to the business customer allowing us to use the deal and send it to our selected brokers?
02/25/2008
Would direct marketing to seniors for reverse mortgages be in violation of ECOA due to advertising to a particular group of people, in this case, age-related?
12/17/2007
Our marketing department wants to offer a skip a payment program to consumer loan customers. They will be sending out a mailer offering the customer the ability to skip one month’s payment during the Christmas holidays. Actually, it will be December through February and the customer can choose the month they want to skip payment. The mailer will explain what happens when they skip a payment, fees, etc. Are there any marketing/compliance issues we need to consider?
11/19/2007
I work for a community bank and am fairly new to banking. I'm looking for an advertising "Bible." I've found some resources and thanks for everything you do, but haven't found anything that's all encompassing. Any help would be appreciated!
11/05/2007
Where can I get new Fair Lending and HMDA posters for the lobby? I have searched the internet, but I know there has to be something I am missing.