Ensuring that your marketing campaigns are in sync with regulatory expectations
We review your advertising for truth and transparency and help you manage the compliance risks associated with marketing your bank.
Think of the ads you most love. Typically, they incorporate a clever play on words, catchy phrases, and memorable images.
A copywriter’s job is to grab readers’ attention and persuade them that investing in a product or service is in their best interest.
But in banking, that approach can overstep boundaries.
You may make promises and use words and phrases that lead you into trouble on numerous regulatory fronts: RESPA, Fair Housing, Truth in Lending, ECOA, UDAAP, and others.
We’re here to review your advertising copy and images, including digital, print, radio, TV, email, billboards, and signage in a way that preserves your brand identity and embraces your creativity, all while preventing you from stepping into dangerous regulatory waters.
Since the devil often is in the fine print, we read for trigger language and red flags and review copy for the nitty-gritty – missing disclosures, required logos, terms and fees, and so forth.
To make developing future ad campaigns less demanding for you, our team can review your advertising manuals, processes, and checklists to be sure they’re providing your creative team the guidance they need to adhere to current regulatory requirements.
TCA’s A Better Way balances your creative vision with regulatory reality.
Key deliverables include:
- Ensuring your advertising is in sync with current regulations
- Providing reviews, and testing copy for regulatory red flags
- Reviewing your advertising manual, guidelines, and policies for their effectiveness and adherence to the latest regulatory thinking
- Offering guidance and training for your creative teams
Additional Compliance Topics
FDIC Name Change – Updated, Again
On August 8, 2022 in the Federal Register (and a correction on August 12) the FDIC reported they had renamed the Consumer Response Center to the “National Center for Consumer and Depositor Assistance”. This Division is referenced in the Fair Housing regulation at 12 CFR 338 and in the Consumer Protection in Sales of Insurance […]
FDIC Insurance – Communication is Key
Because of the recent Bank failures, your customers may feel skittish today. Although the news pundits all are saying deposit accounts are insured up to $250,000, we know this may not be the case. Consider having Management craft a statement message or online banking alert assuring customers their funds are insured. You should also ensure […]
FDIC Name Change – Updated
On August 8, 2022 in the Federal Register (and a correction on August 12) the FDIC reported they had renamed the Consumer Response Center to the “National Center for Consumer and Depositor Assistance”. This Division is referenced in the Fair Housing regulation at 12 CFR 338 and in the Consumer Protection in Sales of Insurance […]
HMDA News and Census Tract Updates
Breaking News!! This week the OCC, FRB and FDIC announced their stance on HMDA reporting for institutions thrown back into HMDA reporting due to the recent Court decision to roll back the closed-end mortgage reporting threshold from 100 back to 25. All three regulators are taking the same stance as the CFPB and have stated […]
CRA Asset-size Thresholds Announced for 2023
The annual CRA asset-size thresholds for covered financial institutions were announced December 19, 2022 by the FDIC and FRB and on December 28 by the OCC applicable for 2023. The cutoff adjustments are based on the change in the CPI (Consumer Price Index) for each 12-month period ending in November, rounded to the nearest million. […]
HMDA and HPML Thresholds Bumped Up for 2023
On December 28, 2022, the Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and the Truth in Lending Act (Regulation Z), adjusting the asset-size exemption thresholds for banks, savings associations, and credit unions. Like the CRA thresholds, the adjustments are pegged to the annual percentage increase in the Consumer Price […]
