I know that tellers and CSRs may offer referrals to our Wealth Management department but what constitutes a referral? Is handing out brochures or business cards (kept in a drawer) permissible? My interpretation of what I have read in the regulatory exam manual is that a brochure is advertising. No reference is given to branch managers. Opinions?

Have you read this:

https://www.fdic.gov/regulations/resources/financial/

Yes, thanks.