[JessicaKlements]

The Bank has recently implemented a direct issue credit card program. Our Business Bankers are requesting that they include an advertisement on all emails above the signature line that states something like ‘Ask about how to apply for a Timberline Bank Credit Card today’ or ‘Now offering Consumer and Business Credit Cards.’

I updated the Bank’s Privacy Notice to state for marketing purposes – to offer our products and service to you – Does the Bank share to Yes. With that, I comfortable with marketing the cards to our customer database but with the emails, we are not always sending those to just current customers. We are sending emails to potential customers and possibly vendors.

I am reading on marketing and see very direct rules relating to marketing for college students. I am not finding anything that may help with the marketing for non-customers based on in this scenario.?.

Are there concerns with advertising the credit card within emails/signature lines?

Any guidance on this is much appreciated.

[rcooper]

It sounds like you are already looking to the Regulation Z advertising rules, including the marketing rules related to college students in 1026.57, and the marketing/opt-out rules related to Reg P and FCRA. You will also need to consider UDAAP and CAN-SPAM. UDAAP affects everything you do and CAN-SPAM relates to email advertisements. You can find information about it on the FTC’s website at: https://www.ftc.gov/tips-advice/business-center/guidance/can-spam-act-compliance-guide-business and https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/can-spam-rule

If you have specific questions once you’ve reviewed these requirements please let us know.

[Author]

Posts