We have a newsletter that gives editorials or generic information about private banking services. This newsletter is put on our website and can be considered an advertisement. The newsletter talks about trust services, estate planning and private banking.

Trusts and private banking can sell products that are non-deposit investment and deposit investment. However the newsletter makes no attempt to sell any deposit or non deposit insurance product or annuity. The past person at this bank had always wanted the non-deposit disclosures under 12 cfr 208.84. I disagree.

Then, section 326 of FDIC regulations says: (c) Use of official advertising statement in advertisements--(1) General requirement. Except as provided in § 328.3(d), each insured depository institution shall include the official advertising statement prescribed in § 328.3(b) in all advertisements that either promote deposit products and services or promote non-specific banking products and services offered by the institution. [b[For purposes of this § 328.3, an advertisement promotes non-specific banking products and services if it includes the name of the insured depository institution but does not list or describe particular products or services offered by the institution. An example of such an advertisement would be, "Anytown Bank, offering a full range of banking services." [/b]

The way I read this, this newsletter requires the Member FDIC disclosure because it is possible to sell either deposit or non-deposit investments through the departments referrenced, but makes no attempt to sell any annuity or non-deposit investment. Please opine.

Are there any articles about products that are available?

Not in the one that I am looking at. That is not to say that there are not any others in pervious ones, but IMO I could modify the disclosure based on the content of the newsletter.