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#2188927 - 08/13/18 07:44 PM Service messages in newspaper
Karen B. Offline
100 Club
Joined: Oct 2014
Posts: 151
We are going to run a series of educational messages in the local newspaper. The messages address a variety of topics--for example, 529 plans, trusts, the importance of communication within the family, budgeting, and retirement plans. The messages don't encourage the reader to come to our bank for these services or assistance; the focus is more on "here are some things you should think about." Our name, website address, and the words "Banking, Mortgage, Retirement, Wealth Management" appear at the bottom. There's nothing saying "contact us for more information." Would a piece like this be considered an advertisement such that disclosures about FDIC membership or the fact that certain products aren't insured would be necessary? This feels like a very gray area. Can you help? Thank you!

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#2188961 - 08/14/18 12:35 AM Re: Service messages in newspaper Karen B.
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Yes, you need it. You mention your bank's name (I assume). That's all that is needed to trigger "Member FDIC".
_________________________
David Dickinson
http://www.bankerscompliance.com

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#2188976 - 08/14/18 11:39 AM Re: Service messages in newspaper Karen B.
Karen B. Offline
100 Club
Joined: Oct 2014
Posts: 151
Thank you, David! I'll get that added.

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#2189020 - 08/14/18 03:51 PM Re: Service messages in newspaper Karen B.
LiveFunLife Offline
Member
Joined: Dec 2017
Posts: 91
So just disclosure of an institutions name triggers it. Thanks for asking Karen it answered for myself as well.

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#2189892 - 08/21/18 02:28 PM Re: Service messages in newspaper Karen B.
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
With that tag line including non-deposit products indirectly, you will also need to include a disclaimer of FDIC coverage (3NOT, MAY).
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2189895 - 08/21/18 02:33 PM Re: Service messages in newspaper Karen B.
Karen B. Offline
100 Club
Joined: Oct 2014
Posts: 151
Thank you, John!

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