The FDIC's advertisement of membership regulation states the following:
Sec. 328.3 Official advertising statement requirements.
(a) Advertisement defined. The term “advertisement,” as used in this part, shall mean a commercial message, in any medium, that is designed to attract public attention or patronage to a product or business.
If you are only calling people that currently have the debit card and just instructing them how to activate it, then it does not seem like it meets the above definition because they already have the product.
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.