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#717433 - 04/17/07 05:22 PM Sales Menu - Disclosures Needed?
SJB Offline
Diamond Poster
SJB
Joined: Jun 2002
Posts: 1,210
California
Our marketing people are developing a "sales menu" (like a restaurant menu) for our branch people to use when discussing products with customers. The menu would be laminated and have info on various accounts, features, etc. The menu would be shown to customers but not given to them to keep.
The question is whether the menu must have all the disclosures we would normally put in a newspaper ad or a flier. Marketing feels the menu is a "sales tool" for internal use and therefore not an ad. I say that since the customer may look at it (but not keep it) it is still an ad and needs all the fine print.
One option proposed is to label it "For Internal Use Only - Not for Distribution."
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#717445 - 04/17/07 05:38 PM Re: Sales Menu - Disclosures Needed? SJB
Confused in Compliance Offline
100 Club
Joined: Apr 2002
Posts: 228
We have the same situation here, and we put that same disclosure on the bottom. I have some of the more important "disclosure" points at the bottom, like APY's good as XXX date, etc... which is more for the Associate to use so they provide the correct information to the customers. But we treat it as an internal document.

Confused in Compliance

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