The bank is purchasing a prospect list of Homeowners within our Assessment Area Zip Code, that have LTV of 80%. This would be the firt time we email consumers who are not existing customers. We have sent emails to customers but not to non-customer. As I understand it, we need to identify that the e-mail message is an advertisement or solicitation. Is this required in the Subject line, the top of the email, the bottom, or doesn't it matter as long as it is there somewhere?

Way back when - there was a "best practice" by some and talk of a requirement of putting "ADV" in a subject line to denote "advertisement" but I don't believe that ever got a lot of traction. A "do not email" like the "do not call list" is the same.

Email spam filters are also better than they were "way back when".

I would recommend keeping some good records for fair lending and CRA of your solicitations, ie. who, where, any prescreening techniques employed, etc.