I did a search and didn't fine anything on this so here goes - -Marketing wants to advertise deposit accounts via Post-It notes on newspapers. Instead of the disclosures on the Post-It note, they just want to say, "See ad inside for more details." I don't think that is sufficient. By analogy, on website ads you can send someone to the disclosures but you have to provide a direct link. With the Post-It notes, having the consumer look through a hundred+ page newspaper doesn't seem to meet the same standard. At a minimum, I think they should include the page number (but they want to print in bulk and use several times.)
Thoughts?

I agree this is not sufficient. You are right that websites can have disclosures "1 click away", but this is the only exception. I don't believe saying "see page __" is sufficient, but you might get away with it.

Thanks David - the more I look at this the less I think the "see page X, etc." saves it. The website exception is a very narrow one to address a new technology. Post-it Note ads may be new but printed ads, which they are, have been around a long time.

The post it could say though... "See page X for blah blah blah!", and then on Page X, have the the great ad.

Otherwise, yep, if trigger is on the post it, so must the fine print and such.