Question & Answer

Question: Our bank offers investment products. The branch where these products are being offered has a small lobby. I know that we aren't supposed to mix advertisements for investment products with our advertisements for deposit products. However, our branch manager would like to use a free-standing display board. One side would be dedicated to deposit products and one side to investment products.

Answer: Although in theory you should be able to design such a two-sided board and be in compliance, we don't recommend it. The reason we don't recommend it is the reality that the brochures will migrate to the wrong side of the display. For example, have you ever been in a card store? All it takes is one customer to mix things up. Cards never seem to stay in their designated slot or section. Card store owners spend their time straightening them out! The same thing will happen to your display. Customers pick up the brochures, glance at them, keep some, and put others back-but not necessarily in the slot they took them from! And that's the problem. Customers don't need to be concerned about the rules-you do. Using a front and back stand is asking for problems. It would be better to get two smaller displays and keep them in separate areas. Promotion of investment products is a particularly sensitive area right now. Careful compliance by banks can prevent the development of burdensome regulation.

Copyright © 1996 Compliance Action. Originally appeared in Compliance Action, Vol. 1, No. 11, 7/96