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Regulators increase scrutiny on marketing
As part of what the FTC has deemed ‘Operation Steer Clear’ (aren’t regulators great at catchy names?) it is bringing a wave of actions against auto dealers for marketing violations. The violations run the gamut from advertising ‘$0 Down’ and hiding key exclusions in the illegible fine print to failing to make required disclosures under Regulation Z. You can read details on ‘Operation Steer Clear’ here and here.
You might think that these are just particularly unscrupulous auto dealers, but many of the violations cited I see in bank advertisements. The Regulation Z marketing rules can be tricky and violations can inadvertently slip through the cracks. Layer on top of that the fact that UDAAP is highly subjective at best, and at worst arbitrary, and you have an area ripe for potential regulatory violations.
Bank regulators have not emphasized marketing compliance in the past, but the FTC’s recent activities combined with possible pressure from the CFPB could indicate a shift towards additional scrutiny. If you think they are going to go after auto dealers and leave banks alone you haven’t been watching the regulatory environment in the past decade.
The good news for banks is that marketing compliance is much less complex than other areas of compliance, like the CFPB’s mortgage rules, for instance. The problem at many banks is that compliance is not a strength of marketers (nor should it be) and compliance staff simply does not have the time to check every marketing piece that goes out the door, particularly within the timeframe requested by the marketing staff. DMTH is launching a solution that will help banks ensure complaint marketing while saving compliance staff valuable time, which is increasingly at a premium.
If you have any marketing compliance questions or would like to discuss whether DMTH can help with your bank’s marketing review process contact Jeff Andersen at 515-246-4515 or [email protected]
Source: http://www.dickinsonlaw.com/2014/03/regulators-increase-scrutiny-on-marketing/
