Use only approved deposit-insurance, credit, and structure language

Marketing Compliance policy, §5.2, §5.3, §5.8

Any statement about FDIC insurance coverage goes to the sponsor bank before use, says clearly and next to the statement that the Company is not an insured depository institution and that coverage protects only against the sponsor bank’s failure, and states the coverage limits. Where the program offers credit or deposits, any triggering term is accompanied by the disclosures Regulation Z or Regulation DD requires, and rates are stated as an annual percentage rate or annual percentage yield. Materials never present the Company as a bank or the issuer of accounts. Any deviation from the pre-approved language requires fresh sponsor bank approval.

Event-driven

Each material that mentions insurance, a rate, a fee, a payment term, or the bank relationship, before publication

Insert the pre-approved disclosure block for the product, check the material for triggering terms and for any wording that implies the Company is a bank, and send any new or changed disclosure language to the sponsor bank before use.

• Pre-approved language library

  Each disclosure block with the bank’s approval date and version

• Disclosure check

  Per material: triggering terms found, disclosure block used, deviation approvals

Compliance Officer

Leela can draft the disclosure block from the approved library, spot triggering terms in a draft, and flag any wording that departs from approved language.

Tell Leela about your company to see whether this applies.