We provide sales tools for our branch staff to use when opening deposit accounts in the office. For instance, a customer comes in to open a checking account and the customer service rep puts on her desk a laminated "placemat" which compares the features of our different products. This is used only as a talking point and not removed from the office or sent to a customer. Would this be considered an "advertisement" and need appropriate Reg DD disclosures?
Thanks for any feedback.