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its annual report. The report went to petitioner's members.
USNB did not expect or require petitioner to mail direct
solicitation materials to satisfy its duty to inform members
about the affinity credit card program.
2. Petitioner's Occasional Assistance to Alumni
After the affinity credit card program began, petitioner
occasionally received requests from alumni for credit card
applications. In each case, petitioner sent a brochure to the
person making the request.
Petitioner received a few complaints from alumni who had
been denied a credit card. Petitioner referred these complaints
to USNB and asked USNB to look into the problem. USNB decided
whether to issue a credit card. On each occasion, USNB told
petitioner that the alumni member was contacted and the matter
handled appropriately.
Petitioner occasionally received requests for credit cards
from persons who were connected with the University of Oregon but
who were not alumni. Petitioner forwarded each request to USNB.
3. USNB's 800 Number for Affinity Credit Card Holders
All advertisements and solicitations asked the recipient to
contact USNB directly. The promotional materials listed USNB's
800 number. It was expected that alumni would contact USNB.
Petitioner maintained a list of USNB employees and their areas of
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