My bank is an affiliate of a holding company that also owns an insurance agency in our market area. I recently saw a marketing brochure of theirs (the bank's Marketing Director acted as a consultant on it) that mentioned they and the bank (using the bank's name) are corporate partners. It also said that togehter we can offer complete financial services. Included in the brochure is a list of the insurance products they offer, i.e., life, auto, property, plus other services, such as IRA's. There are no FDIC or NDIP disclosures in the brochure.

Do we have a regulatory issue? What is the fine line when disclosures are required?

I feel that disclosures are needed and am having a variety of discussions with the Marketing Director over this. He feels it is the insurance agency's marketing information and does not affect the bank, therefore we should not be concerned or have input in the materials.

Would it make a difference if the brochure was not placed in the lobby of our branches?

Your thoughts are appreciated.

Disclosure is the safety net here. Dealing with insurance or investment products (non-FDIC insured) need to be disclosed as such, i.e. may loose value, not FDIC insured, ect.
This is especially true when cross marketing by using both the Insurance Agency and The Bank in the pamplets or advertisements.

I agree, disclosure is very important. What concerns me most about your question is the marketing director is making the insurance partner responsible. Banks have a strong trust factor, if nothing else, from customers. To suggest that if something goes wrong or there are customer complaints they should be taken up with the insurance partner, is bad. Disclosure requirements or not, be proactive in your customer relationships. Banks can and are making good fee income from selling insurance. Don't get started on the wrong foot.