Quality Assurance Checklist for Marketing Disclaimer Information. Do Your Marketing Disclaimers Contain The Following Information?

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1 Quality Assurance Checklist for Marketing Disclaimer Information To help you create consistent and accurate marketing disclaimers, we ve broken down the necessary information into subcategories. To use the checklist, start with the subcategory, then check off the statements that you ve included in the marketing disclaimer. For example, if your marketing materials contain an account opening bonus you would check the boxes below Account Opening Bonus Information as you proofread or create your disclaimer. If your materials didn t mention an account opening bonus, you would skip to the next subcategory. There are a few subcategories we recommend you always include. Do Your Marketing Disclaimers Contain The Following Information? Account Opening Bonus Information o The amount of the bonus o The eligible audience for the bonus o Specific locations where the account must be opened in order to receive the bonus o The timeframe within which the account must be opened to qualify for the bonus o Any minimum deposit required to open the account o Any minimum balance require to obtain the bonus o Any limitations on how many accounts that can be opened by a consumer / household o Any limits on the number of account opening bonuses that may be received in a calendar year o When the bonus will be distributed o The bonus is considered to be interest o The bonus can / cannot be used toward your opening deposit o The bonus will be deducted at closing if the account is closed within a specified period of time

2 Qualification Information If mentioning a product, then check to be sure your disclaimer includes the product-specific following information: o All of the transactions and activities that must post and settle to the account during the Monthly Qualification Cycle in order to earn the account s rewards. Bullet points must contain specific restrictions if any that are applicable to each qualifier: o Have at least [XX] [direct deposit / ACH credit] transactions post and settle o Have at least [XX] [PIN-based, signature-based] debit card purchases post and settle o Have at least [XX] bill pay transaction(s) post and settle o Maintain a valid address on record with [FI Name] o Be enrolled in and agree to receive e-statements o Be enrolled in and log into online banking o Be enrolled in and log into Kasasa 360 o Any limitations associated with the size of the debit card purchase in order to count toward earning the account s rewards (for non-interest bearing accounts) o Account transactions and activities may incur a lag between the time the transaction was physically / electronically conducted and the time that it is posted and settled to the account o Any typical account transactions that do not / will not count toward earning rewards o Monthly Qualification Cycle (MQC) definition o Any other timeframe definitions (i.e. Business / Banking Days; Statement Cycle) if you feel they are not commonly understood by your account holders

3 Account Rewards o The account s rewards when qualifications are met during the Monthly Qualification Cycle (MQC). o o Statements should fully describe all rewards including any restrictions / caps as to the amount the account holder can expect to receive during any qualifying cycle period Statements should communicate any impact of any linked accounts rewards o What the account holder receives / does not receive when qualifications are not met during the MQC o When the account holder will receive his / her rewards ATM Fee Reimbursements o The maximum amount per withdrawal transaction that will be refunded if qualifications are met during the MQC o Any action the account holder may have to take to receive full refunds o Who within / how to approach the institution if the account holder has any questions o What the account holder receives / does not receive when qualifications are not met during the MQC o When the account holder will receive his / her rewards Rate Information o APY = Annual Percentage Yield if a rate on an interest-bearing account is featured in materials o Rates and rewards may change after the account is opened if it is a variable rate account o Fees may reduce earnings

4 Account Characteristics / Conditions o Any minimum deposit required to open the account o Any conditions associated with the account holder having the account o The account is not to be used for commercial purposes o Any limitations as to how many accounts an individual / household can open / have o The account does / does not have any recurring service charges or fees o Account approval, conditions, limits, timelines, enrollments, log-ons and other requirements apply o Enrollments in & utilization of some services may be required in order to earn rewards Additional Information o How consumer can receive more information/details from a knowledgeable resource o Any sources if comparison claims are made o Insurance coverage, i.e. [Member FDIC, Federally Insured by NCUA] Trademark Information o All proper Kasasa trademarks o Proper trademarks for any third-party vendors that are mentioned or shown in the marketing materials. o Third-party vendors are / are not participants / sponsors in the account / program

5 We ve Created A Quality Assurance Checklist To Assist You To Develop Your Own Marketing Disclaimers: The checklist was created to provide community financial institutions with a simple checklist to ensure your Kasasa marketing disclaimer information satisfies Truth In Savings requirements and to address potential UDAAP misinterpretation by examiners who may be unfamiliar with how Kasasa accounts work. This checklist is not meant to be a comprehensive list of all regulatory requirements nor does it necessarily reflect your institution s compliance philosophy. Each disclaimer must be customized to match your institution s product offerings, processing methodologies and compliance philosophy. Your Institution Is Ultimately Responsible For Adhering To All Regulatory Requirements: Additionally, since BancVue is not engaged in rendering legal, accounting, tax, or professional compliance advice, this checklist and the language contained within any sample disclaimers we provide should not be considered or used as a substitute for consultation with and guidance from your institution s Compliance Officer, outside consultant, or legal counsel.