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News Release 2002-30
March 22, 2002
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ANNAPOLIS, Md. — New guidance issued by the Office of the Comptroller of the Currency will help banks maintain high-quality customer service, said Julie L. Williams, the OCC's First Senior Deputy Comptroller and Chief Counsel.
The advisory letter on unfair or deceptive acts or practices "is part of our effort to identify potentially problematic practices and provide guidance to national banks on how to avoid them," Ms. Williams said in a speech before a compliance conference sponsored by the Maryland and Delaware banking associations.
Ms. Williams said compliance is an essential — but not the exclusive — element of a bank's overall strategy for good customer service.
"Individual consumers may not know precisely if their bank has complied with all the applicable compliance rules, but they immediately know, and have no problem reacting, when they feel they haven't been treated right by their bank," Ms. Williams said. The OCC's new advisory letter should help banks ensure that their marketing operations comply with Section 5 of the Federal Trade Commission Act, which makes it unlawful to engage in unfair and deceptive acts or practices, Ms. Williams said.
Ms. Williams said the guidance includes a number of common-sense tips for avoiding practices that could cross the line from being bad customer relations to become unfair or deceptive practices, including the following recommendations:
"We should not expect consumers — even financially sophisticated consumers — to have to read marketing and other information for hidden meaning, or obliquely stated conditions and limitations, as if they were trained investigators — or heaven forbid — lawyers," Ms. Williams said.
"Instead, banks can use their position as trusted and highly respected businesses to promote first class customer relations and the highest integrity in marketing practices for financial products and services," she added. "Take a look at the guidance in our new Advisory. Review your marketing materials and practices, and take the steps you need to 'get it right.' It will help keep you out of trouble — and it's good business."
The advisory letter on unfair or deceptive acts or practices can be found on the Internet by going to the OCC's home page at www.occ.treas.gov and clicking on issuances and advisory letters.
Robert M. Garsson (202) 874-5770