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Marketing by nonbanks of products and services offered with bank partners is coming under increasing scrutiny that focuses on the potential for consumers to be led to believe that the nonbank is a bank, or is FDIC insured. We discuss recent state and federal regulatory and enforcement developments, including the FDIC’s proposed rule addressing false advertising, misuse of the FDIC logo, and misrepresentation of insured status, and state regulators’ and federal lawmakers’ interest in the issue, and offer takeaways for banks and nonbank partners on what these developments mean for their marketing efforts.
Chris Willis, Co-Chair of Ballard Spahr’s Consumer Financial Services Group, hosts the conversation, joined by Mindy Harris, Of Counsel in the Group.
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Marketing by nonbanks of products and services offered with bank partners is coming under increasing scrutiny that focuses on the potential for consumers to be led to believe that the nonbank is a bank, or is FDIC insured. We discuss recent state and federal regulatory and enforcement developments, including the FDIC’s proposed rule addressing false advertising, misuse of the FDIC logo, and misrepresentation of insured status, and state regulators’ and federal lawmakers’ interest in the issue, and offer takeaways for banks and nonbank partners on what these developments mean for their marketing efforts.
Chris Willis, Co-Chair of Ballard Spahr’s Consumer Financial Services Group, hosts the conversation, joined by Mindy Harris, Of Counsel in the Group.
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