Our affiliate insurance company wants us to provide info(advertise) by mail to our customers. We will not provide any customer info to the affiliate. The fact that the insurance company is our affiliate will be disclosed and the "not,not" disclosure included. Is this ok?

Wait, your insurance company wants to advertise by mail to your customers... you will not provide any customer info to the affiliate... how is the mail going to be delivered if the name and address is not shared?

I believe OTE is saying the bank will mail the advertising info for their affiliate ... i.e., the ad will be coming from the bank so they don't run into the FACT Act affiliate marketing opt-out issue.

The bank will either do a separate mailing or will include with stmts.