Is a product description within an online account portal considered an advertisement for TIS purposes? For example, when you are choosing your accounts to open, the description reads "5 Year CD Special - Earn a higher rate of return at 2% APY on your funds." You could then click "More Information" to get more information and it takes you to another screen where you get a bit more description. I am wondering if we should have all required TIS advertising disclosures at that second screen? If they don't click on "More Information" it will provide them with the full TIS disclosure when they move to the next section. However, is this even a consideration if it is not an advertisement?