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#910445 - 02/26/08 04:54 PM Affiliate Marketing Question
upstateNY Offline
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Joined: Apr 2003
Posts: 933
New York State
I just need a little comfort level. Bank A has a list of established customers that affiliate B would like to market its products to. None of these customers are customers of affiliate B.
Can we avoid the opt-out requirements by introducing affiliate B, its contact and product information, in a solicitation made on Bank A's letterhead and from Bank A?

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#910922 - 02/27/08 12:22 AM Re: Affiliate Marketing Question upstateNY
GuitarDude Online
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GuitarDude
Joined: Nov 2004
Posts: 5,924
So Cal
I think you would be OK having Bank A soliciting its own customers. You probably want to make it clear that the products being marketed are not being offered by Bank A.
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#930713 - 03/26/08 06:44 PM Re: Affiliate Marketing Question GuitarDude
upstateNY Offline
Platinum Poster
Joined: Apr 2003
Posts: 933
New York State
The rule allows us the exception to opt-out through Bank A introducing Affiliate B in a letter, per above. However, it does not go on to clarify whether or not this opens the door for Affiliate B to go ahead and solicit the customer.

Can Affiliate B then contact the customer? Any thoughts?

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#930904 - 03/26/08 09:12 PM Re: Affiliate Marketing Question upstateNY
corkygirl Offline
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Joined: Sep 2004
Posts: 4,241
middle of the country
I dont' think that Affiliate B can then contact the customer. I think it's up to the customer that might be interested in what Affiliate B is offering to contact Affiliate B. JMO
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