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Dos:

  • Do describe clearly, prominently, and accurately:
  • Costs, benefits, and other material terms of the products or services being offered
  • Related products or services being offered either as an option or as a requirement
  • Material limitations or conditions on the terms or availability of products and services, such as time limitations for favorable rates, promotional features, expiration dates, prerequisites for obtaining particular products or services, or conditions for canceling services
  • Be honest regarding the obtainability of a product, service, and/or interest rate
  • Maintain consistency between marketing materials, verbal sales communications, and how things actually work
Disclosure TextBe sure to include disclosure text such as:
  • [FinTech] is a financial technology company and is not a bank. Banking services provided by [Sponsor Bank]; Member FDIC.

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Don’ts

  • Don’t refer to the FinTech as a “bank”, unless your FinTech is in fact a licensed banking institution
  • Don’t rely too heavily on fine print, separate statements, or inconspicuous disclosures to correct more prominent statements that are potentially misleading 
  • Example: If the main large print of an advertisement lists a product as free, but the fine print details that it’s not actually free because there are a listing of fees and charges that actually cost the customer something to obtain or use the advertised product or service, then this is potentially misleading. In other words, the advertisement has relied on the large print to pull in the customer, and attempted to clarify in small print something different, which may easily be ignored by the customer.

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How to notify your Sponsor Bank

Use Synctera Cases to notify your Sponsor Bank on any marketing materials you’d like to publish. Details on how to use the marketing materials case can be found here. As a rule of thumb, provide the Bank with at least 2-weeks notice to review and approve the materials.