Would anyone happen to know or have any regulatory information/guidance on digital marketing using Google, Facebook, and the like? Marketing is wanting to utilize digital advertising for a money market product that has a minimum opening balance of $50k and limit it to upper income households. These parameters would be filtered in the digital medium used to advertise. Obviously, for credit products, ECOA and fair lending redlining comes to mind but for deposit products, there isn’t too much I am able to find or pinpoint as regulation has not caught up to digital marketing as of yet.
I think you can utilize targeted marketing for deposit advertisements without the same fair lending risk associated with lending products. However, I would recommending ensuring that your overall marketing strategy is inclusive of all areas and demographics. As you mentioned, regulations have not kept up with marketing tools and we don’t have a lot of information from regulators on digital marketing; however, I think the rules and expectations applied to more long standing marketing tools also apply to digital marketing. This is the perfect example of a good opportunity to have a discussion with your examiners to determine their views since they will be the one evaluating your practices.
There was a good article on digital marketing in the Jan./Feb. 2019 edition ABA Bank Compliance publication. If you are CRCM you have access to it for free. I believe ABA members may also have access.
Thanks for the update Robin. I was able to download the magazine. I am a few months behind on my reading so thanks for the push to read it. I am meeting with our marketing team in the morning so they can take me behind the scenes of Google ads so I can see all the bells and whistles they have access to. From the content we go through, I can then build on that and update related procedures. Additionally, I will inquire further once the examiners are on site.