Good morning, am I correct in stating if a web page or brochure lists the features of a product, and one of those features is a triggering term, full disclosures are required? For example, listing the term range of 5-30 years on a closed-end would trigger full disclosures, correct? The issue is trying to convince marketing that this is considered an advertisement and Reg Z advertising requirements must be met. If anyone would be able to confirm or prove me wrong, I would be appreciative. Thank you and have a great day!

Does your marketing department really believe that the bank publishes account features for any reason other than to promote it to the public? If it's on a web page or brochure that the public can access, it's an ad.

You would be surprised how marketing defines "marketing" at times, especially when compliance requires additional disclosures or changes to any material :-) Just wanted to get the opinion of an expert. Thanks!