Our bank's Wealth Management Division consists of our Trust Company, Investment Company, and Insurance Company. All are affiliates of the bank. Wealth Management also includes Private Banking under its umbrella. Our Marketing Department wants to run an ad that is directed at other businesses and is primarily related to insurance (i.e. talks about health insurance and voluntary benefit products that we offer. Also mentions that we can help streamline services by bundling services such as deposits, lending and 401k contributions).
Even though the copy of the ad is only for insurance, our Marketing team wants to include the words Trust, Investments, Insurance, Private Banking at the bottom, just to show what is offered under the Wealth Management Umbrella.
We've included the Not, Not, May disclosures, but would we also be obligated to identify all of the affiliates I mentioned since they actually offer the products that we are listing generically?
Also, since our Private Banking would offer both FDIC and non-FDIC insured products, would we have any disclosure obligation there? We don't talk about Private Banking at all in the ad, other than generically mentioning it along with Trust, Investments, and Insurance.