We are wanting to send customers a postcard to promote our Wealth Management Department that lists their products and services they can offer. These have to say that they are Not FDIC Insured, May Lose Value and No Bank Guarantee, correct. Is there anything else that needs to be disclosed?

Joeball, not knowing what else the postcard says makes it very difficult to give any meaningful advice.

The disclosures you put on the postcards you are sending out depends first on a couple of things.

1) Are you offering the Wealth Management Products as a separate devision or department of your bank, or are the being offered by a separate wholly-owed owned subsidiary such as a brokerage or Registered Investment Advisor affiliate?

2) Does the content of the postcard describe the products offered through your Wealth Management area or only the services that they provide?

My thoughts and experience are this:

If no products are being offered,only informing potential clients of the services available, and the Wealth Management Activities are being done as a division or department of your bank - then no disclosure is necessary. If however, you are highlighting certain investment products the Not-Not-May disclosure would be appropriate. Also, if the Wealth Management services are being provided by a subsidiary, you would need to adhere to the disclosure requirements of the NASD, the SEC, or your State Securities Regulator, as appropriate to your specific situation.

Finally, DO NOT include the Member FDIC or the Equal Housing Lender logo!

The postcards only inform potential clients of the products offered through the Wealth Management Department.

Thanks for your comments.