We are sending a letter to all of our customers who have a certain deposit account. In the letter, we tell them their APY is increasing and then we "remind" the customer of all of the "free services" that come with the account. Among them are 2 loan products with no annual fee:
*No annual fee for VISA (upon credit approval)
*Overdraft line of credit with no annual fee (upon approval)
We are not advertising courtesy overdraft protection so my take is that this letter is NOT an advertisement under Reg D or Reg Z, correct? If correct, then stating the above 2 items is fine. If not, and this would be an "advertisement" for loan purposes, stating "no annual fee" is NOT a trigger in either case. Right? Thanks!
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