I am new to compliance and my marketing committee actually showed me an ad this time before sending it out! Here is my question. Can they send out postcards to current 1st REM holders with an advertisement that they can save $75 on closing costs on a HELOC (Which the marketing committee will reimburse to the loan department). Any thoughts on this?? Thank you for your time.

Is the $75 back different than the other ads (presuming there are others) with the same benefit? We offer $$ off when people close on HELOCs if they close within a certain ## days (which we disclose) and the offer is only good for a certain period of time (which we disclose).

Only in that we are getting reimbursed from another part of the bank, and that we are sending them to current 1st REM holders.