We quite often have a valid date on our marketing materials, most likely to prevent an old piece being discovered and rate or product info is old. Our marketing department has asked if there is another way we may not specify an exact date so we can reuse pieces if the information is not changed.

I believe since we always include language similar to 'programs, terms and conditions may change...', we could not include a valid date. Unless of course there was something that drove that date range, like a promo rate.

I would appreciate feedback on that thought. Or, if you have some fancy language you include and are willing to share, that would be great too.

Thank you!

Do these marketing materials relate to deposit products, credit products, or both?

I'm not entirely sure what you mean by "valid date." Our marketing keeps a log of product cards and brochures, each of which has a date on it. Until something changes which causes us to change the wording on the brochure, the date will remain. Anything specific, such as deposit rates, promotions, etc. are changed frequently and the dates are almost always within a couple months of the current date. On the flip side, we have a couple of very broad, very generic product cards without anything even remotely specific. We have a loan card with a picture of a super-imposed $ with the wording "Need a loan? Meet with one of our loan officers today." That's it...that's the entire advertisement. We have the EHL logo and the FDIC logo. It was last updated in 2007, but it's still the most current ad of that particular type.

Seeking some wisdom from the compliance universe.

My FI is sitting on a sizeable quantity of pretty nice looking printed advertising collateral, all of which advertises credit, some of which advertises both closed-end non dwelling-secured loans and open-end non dwelling-secured lines...personal loans and lines.

We're contemplating a rate change, and my question is this: w/r/t the closed-end credit products, which is where we're currently looking at boosting rates, we have some mouseprint that reads "Please visit XXX.com for current rate information." There is nothing to the effect of "Rates current as of..." For the open-end products, there are no such disclosures saying "Rates current as of..." or anything else.

So as to not have all this collateral become junk, would it be feasible, if not ideal, to place stickers on the covers of multi-page brochures saying something to the effect of "Rates current as of XX/XX/XXX. Please visit XXX.come for current rate information"?

Any clarity or creative thinking welcome and much appreciated. Trying to balance compliance and business realities. This collateral wasn't produced on my watch, so it's an opportunity for me to fix things going forward.