1(b) Product and Service Offerings Does the Bank or service any of the following products? Add-On Product (e.g., identity protection or credit protection) Secured / Subprime Credit Cards Subprime or High Cost Mortgages Non-Traditional Mortgages negative amortization) Gift Cards Fee-Based Overdraft Protection Plans Payday, Deposit Advance or Tax Refund Anticipation Loans Prepaid (e.g., Gift, Travel or Payroll cards) Reverse Mortgages Student Loans Other new and non-traditional banking products or services Rewards or Bonuses Remittances Balance transfer credit cards through Independent Service Organizations (transfer of due or charged-off consumer debt) Unsecured loans originated through a debt-relief third party Age-based deposit product with a credit feature Do different products or services penetrate geographic or consumer markets differently? Does the bank have an aggressive sales or cross-selling culture? Does the bank set sales goals and sales incentives? Are there significant repercussions for not meeting sales goals? Can consumers apply for a specific product or service and end-up with a different product or service than that requested? Does the bank place holds on any deposits? 1(c) Complexity of Products and Services Does the bank offer inexpensive basic checking and savings products? Does the bank’s product mix include any that are complex in nature? Do any of the bank’s products require customers to jump through complex or non-transparent hoops to obtain a benefit? Does the bank offer any traditional products or services with non-typical features or requirements? Is pricing structured or products bundled in a way that makes it difficult for consumers to understand? 1(d) Delivery Channels How does the bank distribute its products? Third Parties Subsidiaries or Loan Production Offices Any which generate business outside its retail footprint? Is the bank utilizing any new delivery channels?
1(b) Product and Service Offerings Does the Bank or service any of the following products? Add-On Product (e.g., identity protection or credit protection) Secured / Subprime Credit Cards Subprime or High Cost Mortgages Non-Traditional Mortgages negative amortization) Gift Cards Fee-Based Overdraft Protection Plans Payday, Deposit Advance or Tax Refund Anticipation Loans Prepaid (e.g., Gift, Travel or Payroll cards) Reverse Mortgages Student Loans Other new and non-traditional banking products or services Rewards or Bonuses Remittances Balance transfer credit cards through Independent Service Organizations (transfer of or charged-off consumer debt) Unsecured loans originated through a debt-relief third party Age-based deposit product with a credit feature Do different products or services penetrate geographic or consumer markets differently? Does the bank have an aggressive sales or cross-selling culture? Does the bank set sales goals and sales incentives? Are there significant repercussions for not meeting sales goals? Can consumers apply for a specific product or service and end-up with a different product or service than that requested? Does the bank place holds on any deposits? 1(c) Complexity of Products and Services Does the bank offer inexpensive basic checking and savings products? Does the bank’s product mix include any that are complex in nature? Do any of the bank’s products require customers to jump through complex or non-transparent hoops to obtain a benefit? Does the bank offer any traditional products or services with non-typical features or requirements? Is pricing structured or products bundled in a way that makes it difficult for consumers to understand? 1(d) Delivery Channels How does the bank distribute its products? Third Parties Subsidiaries or Loan Production Offices Any which generate business outside its retail footprint? Is the bank utilizing any new delivery channels? due
UDAAPRiskAssessmentMatrixFINAL.docx