Where a bank's marketing becomes a matter for its risk committee

I plan deposit communication for a confidence event before one begins, because the first day decides most of what follows. At Ledgemoor that means a prepared facts page, refreshed each quarter with figures the company has already disclosed: the insured and uninsured shares of deposits, the number of accounts above the insurance limit and the categories of liquidity available to us, described without promises. It means a one-page script for 1,400 branch and contact-centre colleagues on how coverage works by ownership category, and a calling plan for relationship managers ranked by balance above the limit. It also means knowing which advertising to stop and who can stop it within the hour. Our chief financial officer, treasurer and general counsel own the figures and the disclosure obligations of a listed company. My role is to make those facts readable within hours, and to keep marketing from saying anything they do not support. We rehearse the plan once a year with the executive committee.

Most rate advertising complies with the rules and still misleads, because the rules govern what must be disclosed while the customer reads the headline. Regulation Z requires a mortgage advertisement that states a rate to give the annual percentage rate, and Regulation DD requires deposit advertising to state yields as annual percentage yields with the conditions that apply. I treat those requirements as a floor. My working rule is that a headline rate must be one the typical respondent will actually receive, recalculated monthly and signed by the people who set the price. A promotional rate shows its duration and minimum balance beside the number, not beneath it. I also read every draft against the broader prohibition on unfair, deceptive or abusive practices by asking what a reasonable customer would believe after five seconds. Product, pricing and compliance colleagues co-own that review. I own the first draft, and the decision to withdraw a claim we can no longer support.

Credit advertising decides who applies, so I treat its delivery as a fair-lending control rather than a buying-efficiency question. Fair-lending law reaches every aspect of a credit transaction, and federal redlining enforcement has looked closely at where lenders market as well as how they lend. At Ledgemoor every campaign for mortgage, home-equity and small-business credit now carries a delivery plan by census-tract group, a ban on bid optimisation by ZIP code and a monthly report comparing impressions, enquiries and applications in each group with that group's share of owner-occupied homes or businesses. Our fair-lending officer co-signs the plan before launch and receives every report. I also review the creative: whether our photographs, languages and branch addresses tell people in every part of our footprint that an advertisement is meant for them. I do not make fair-lending legal judgements. I make sure the colleagues who do can see what our advertising actually did.

Paying someone else to talk about a financial product is still advertising, and I design those programmes as if every post were our own. At Quillmark I rebuilt a 54-creator programme so that creators received flat fees, every paid post was approved by a registered principal before publication and archived, and no paid content discussed trading strategies or returns. FINRA's rules on communications with the public, its guidance on third-party content and the FTC's guidance on endorsements point the same way: if a firm pays for or shapes the content, it owns it, and viewers must be able to see the relationship. At Ledgemoor we pay two creators flat fees to explain deposit insurance and emergency savings, with no account links. The same test applies to customer referral bonuses and to partnerships with employers, housing counsellors and professional associations. I ask what the payment structure makes the partner want to say, and I change the structure before I edit the words.

A bank's marketing is only as fast as its compliance review, and a slow review tempts product teams to route around it. When I arrived at Ledgemoor, advertising took a median of nineteen business days from submission to approval, and some product teams were placing digital advertisements through their own agencies. With our chief compliance officer I sorted materials into three tiers by risk, wrote pre-approved language for recurring claims such as deposit insurance coverage and rate disclosures, and put marketing, legal and compliance reviewers in one weekly session for complex items. Median approval time fell to six business days, and all paid advertising now runs through one agency contract and one archive. Twice a year I report submissions, rejections and withdrawals after launch to the board risk committee. A withdrawal after launch is the plainest sign that the process missed something, so I explain each one rather than reporting the total alone.