08/18/2008
What are the penalties if a bank goofs up and places a loan ad in the paper that says $500 down and leaves off the proper disclosures that are required for trigger terms?
04/21/2008
Is it permissible to advertise a private insurance carrier's logo (indicating additional deposit insurance coverage) next to a Federal Logo (such as FDIC or NCUA)? Example: "Deposit accounts insured up to $250,000 by (private carrier) and Deposit accounts insured to $100,000 by NCUA for a total of $350,000"
10/22/2007
We have the new FDIC signs in place, but a comment in the 10/09/07 BOL Compliance Briefing suggests that the FDIC logo used in deposit product advertising has also been changed. BOL writes, "Ensure you have the new signage posted and that your Marketing Department has the correct logo to use in advertisements." Has the logo been changed too?
08/13/2007
Many of the assumed name certificates that are brought in will have sole proprietorship and a sole practitioner. What is the difference between a sole proprietor and a sole practitioner?
08/06/2007
One of our customers had two CDs each placed with two separate minority owned banks. The two banks recently merged and now the total deposits exceeds $100,000. Does the fact that the CDs were originally in these two separate financial institutions have any bearing on insured deposit coverage?
07/02/2007
Regarding advertising compliance, what about telephone hold messages that advertise our products? Do we need to include the verbal statement "Member FDIC"? Hold times vary, so the customer may or may not hear the entire ad.
06/25/2007
We are designing a brochure for our gift card program. We work with a vendor on this program; the vendor receives part of the fee for a card purchased and the bank receives the remainder. We sell these cards to both customers and non-customers. A gift card does not fit the definition of an "account" under TISA. Would we have to disclose the fees on the brochure? Could we say "ask about the fees" or do we have to disclose the fee schedule? Or could we be silent on the fees? Or is this a deceptive advertising practice? I am also reviewing the contract with the vendor to see if the vendor requires us to disclose fees when advertising.
05/28/2007
We are designing a brochure for our Gift card program. We work with a vendor on this program; the vendor receives part of the fee for a card purchased and the bank receives the remainder. We sell these cards to both customers and non-customers. A gift card does not fit the definition of an "account" under TISA. Would we have to disclose the fees on the brochure? Could we say "ask about the fees" or do we have to disclose the fee schedule? Or could we be silent on the fees? Or is this a deceptive advertising practice? I am also reviewing the contract with the vendor to see if the vendor requires us to disclose fees when advertising.
05/14/2007
We are publishing a program ad which includes logos of all of our companies underneath the name of the holding company. The four companies are two banks, one insurance agent and one broker dealer. This ad contains no specific product information. I have received conflicting advice on including the FDIC and DIF logos. I have been told that if the bank name appears they should be included, but if the investment and insurance logos are included they should not, is this correct?
04/09/2007
I have heard that the revised regulations for advertising membership in the FDIC no longer exempt ads for loans. Is that correct, and was a similar change made to the NCUA regulations?