2(a)(2) Advertisement
1. Coverage. Only commercial messages that promote consumer credit transactions requiring disclosures are advertisements. Messages inviting, offering, or otherwise announcing generally to prospective customers the availability of credit transactions, whether in visual, oral, or print media, are covered by Regulation Z (12 CFR part 1026).
i. Examples include:
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H. Letters sent to customers or potential customers as part of an organized solicitation of business.
* * *
J. Communications promoting a new open-end plan or closed-end transaction.
--- (Comment 2(a)(2)- to Reg Z, emphasis added.
The bank is hoping to get added business from the mailing. There is no way it would not be an advertisement.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8