We have an affiliate company for NDIP products. Bank personnel were given a list of criteria for target customers to refer to the affiliate. (No affiliate marketing agreement w/ FACTA opt out, etc) Bank will call customers who meet the criteria to see if they would like to come in an meet with someone to discuss some investment options.

The call script includes "when is good time for you to come in and hear about our program" - I don't see in the script that they are told they will be meeting with a representative of our affilate company - am I wrong in thinking that they need to inform the customer that it's an affilate? If so, does the customer need to be given a written disclosure of the elationship?