UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION

In The Matter of

DBC FINANCIAL, INC. a corporation.

DOCKET NO.

COMPLAINT

The Federal Trade Commission, having reason to believe that DBC Financial, Inc., a corporation ("respondent" or "DBC Financial"), has violated the provisions of the Federal Trade Commission Act, and it appearing to the Commission that this proceeding is in the public interest, alleges:

1. Respondent DBC Financial is a Delaware corporation with its principal office or place of business at 75 Piedmont Ave., Suite #202, Atlanta, GA 30303.

2. Respondent has advertised, offered for sale, sold, and distributed automated teller machine ("ATM") bank card services to the public, including the Delaware Bank Card. The Delaware Bank Card is a direct deposit ATM bank card.

3. The acts and practices of respondent alleged in this complaint have been in or affecting commerce, as "commerce" is defined in Section 4 of the Federal Trade Commission Act.

4. Respondent has disseminated, or has caused to be disseminated, advertisements and promotional materials for the Delaware Bank Card in direct mailings and on television, including but not necessarily limited to the attached Exhibits A and B. These advertisements contain the following statements:

A. "Because you receive a Government Benefits Check, here is your PRE-APPROVED Delaware Bank Card: The Card that puts CASH in your hands. With this card, you get the following benefits: Automatic Deposit of Your Check! . . . $1,000 Overdraft Protection per Year! With the Delaware Bank Card you have access to Extra Cash when you need it (even when your account balance is $0.00)"

B. "Best of all, because you are Pre-Approved, there are no up front fees required to take advantage of this offer."

C. "If you receive social security, SSI or VA benefits, you are preapproved to receive the Delaware Bank Card. The card that puts cash in your hands. With the Delaware Bank Card, your money gets direct deposited automatically on checkday. No waiting for the mailman. Instant access to your money at thousands of ATM's. With the card you also get a thousand dollars per year of overdraft protection. Call 1-800-784-2600 to sign up today. Guaranteed approval. No upfront Fees. It's simple, it's fast, it's that easy."

5. Through the means described in Paragraph 4, respondent has represented, expressly or by implication, that:

A. Use of the Delaware Bank Card requires no upfront fees.

B. The Delaware Bank Card is affiliated with a United States government agency, institution or program.

C. Use of the Delaware Bank Card automatically provides free overdraft protection services of up to $1,000 a year.

6. In truth and in fact:

A. Use of the Delaware Bank Card requires an "Account Set-Up Fee" of $19.95, as well as a monthly service fee in the amount of $9.95.

B. The Delaware Bank Card is not affiliated with any United States government agency, institution or program.

C. The Delaware Bank Card charges an overdraft protection fee of $19.95 for every month in which the consumer's account is overdrawn by up to $80.00.

Therefore, the representations set forth in Paragraph 5 were, and are, false or misleading.

7. The acts and practices of respondent as alleged in this complaint constitute unfair or deceptive acts or practices in or affecting commerce in violation of Section 5(a) of the Federal Trade Commission Act.

THEREFORE, the Federal Trade Commission this day of , 2000, has issued this complaint against respondent.

By the Commission.

Donald S. Clark
Secretary

SEAL: