Santander Bank: What To Do to get $300?

As competition in retail banking increases, brick-and-mortar banks continue to offer incentives in the form of bonuses to open an account. I recently wrote about TD Bank’s self-mailers. This one from Santander Bank is a simple postcard—in fact, it’s too simple. That’s why it merits a Fail for Creative.

Santander New Customer Postcard
Postcard Front
The front of the postcard prominently messages the opportunity to get a $300 bonus for moving to Santander Bank, but does not explain what that means. The only hint of an explanation is a small message to “See reverse for important information.”

Santander Bank New Customer Offer
Postcard Back

The back of the postcard communicates some of the benefits of banking with Santander and includes a Call to Action to visit a website or visit a nearby branch with the postcard. That’s nice, but what about that $300? What does a prospective customer need to do to get the bonus? The explanation is buried in the long Disclosure. (If you can read the explanation without visual support, you don’t need glasses.) While the 17-line Disclosure is concise, it is not clear to a casual reader. That lack of clarity is a Fail, because who wants to put on reading glasses just to figure out what hoops to jump through to get the bonus?

I’m not a lawyer, so this isn’t legal advice. As a marketer, however, I think the lack of clarity may not only be bad marketing, it may also be a violation of FTC regulations. Current regulations state
“When making ‘Free’ or similar offers all the terms, conditions and obligations upon which receipt and retention of the ‘Free’ item are contingent should be set forth clearly and conspicuously at the outset of the offer so as to leave no reasonable probability that the terms of the offer might be misunderstood.” 
While the terms of the offer to get the free $300 are clear, they are not conspicuous. The offer landing page explains the terms adequately; however, it refers the customer back to the postcard.

Top of landing page

When presenting an offer to a prospective customer, clearly and conspicuously explain what needs to be done to obtain that offer.