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Our marketing department wants to purchase a mailing list to use to USPS mail postcard deposit account advertisements. The unfiltered list is long, so they have asked if it is ok to filter the list to reduce the number to make it more manageable since our bank is located in a very populated area. Options for the filter include by income, location, renter, homeowner, etc.. Are any of these filters permissible? What filters are not allowed? Is there FDIC guidance on this? What rule or reading material covers this?
The available filters are age, income, gender, marital status, homeowner/renter, home value, households with children, length of residence, and year home built.
There is no formal guidance on filtering. However, you must consider UDAAP, Fair Lending and Fair Banking when you utilize filters to narrow down marketing. For example using home value and income standards are a sure way to have a CRA and fair lending issue. Using Age (except for legal contract age), gender, and marital status are protected class categories which will cause fair lending and fair banking issues. In some cases using households with children could also cross the fair lending line.
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