When it comes to advertising your deposit products and services, there are a lot of things that must be taken into consideration. For example, does the ad mention any triggering terms that require additional disclosures, what’s required for the specific medium being used (newspaper, television, radio, online, billboards, etc.), is the ad clear and accurate?, etc. The Truth in Savings Act (TISA) states that deposit accounts cannot be advertised as “free” or “no cost” if a maintenance or activity fee could be imposed on the account. Specific account services or features can be advertised as “free” if no fee is imposed for that service or feature. For example, institutions offering an account that is free of deposit or withdrawal fees could advertise that fact, as long as the advertisement does not mislead consumers by implying that the account is free and that no other fee (a monthly service fee, for example) may be charged.
We recommend financial institutions always use caution any time the term “free” is used because there is also a little thing called UDDAP (Unfair, Deceptive or Abusive Acts or Practice) that may be a factor, as well.
David explains more about maintenance and activity fees in the video.
Video Highlights:
- If a deposit account is advertised as free it cannot have maintenance or activity fees, such as any minimum balance fees or transaction/service fees.
- Other fees, such as check printing, balance inquiries, stop payments, etc., are not considered maintenance or activity fees.
Published
2023/12/08
