Walks like a duck, quakes like a duck. Just because you hang a sign around it's neck that says "I'm a cow" does not make it so.
If this is not a advertisement, ask them why are they sending it. It is not a required regulatory disclosure. Have the information from the Reg Z commentary below when you ask them.
Section 226.2óDefinitions and Rules of Construction
2(a)(2) Advertisement .
1. Coverage . Only commercial messages that promote consumer credit transactions requiring disclosures are advertisements. Messages inviting, offering, or otherwise announcing generally to prospective customers the availability of credit transactions, whether in visual, oral, or print media, are covered by Regulation Z (12 CFR part 226).
i. Examples include:
D. Direct mail literature or other printed material on any exterior or interior sign.
H. Letters sent to customers or potential customers as part of an organized solicitation of business.
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