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#1399281 - 06/03/10 06:21 PM Informational Piece
BankingNut Offline
Member
Joined: Apr 2010
Posts: 90
Does informational material qualify as advertising? The question really is, do we need to have the member FDIC for informational materials sent to customers.

We are doing a voicemail blast to customers instructing them how to activate new cards. It does not advertise any deposit products, but does reference the debit card. Thoughts?

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#1399473 - 06/03/10 09:26 PM Re: Informational Piece BankingNut
Reads Regs Offline
Diamond Poster
Joined: Nov 2004
Posts: 2,310
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.
_________________________
Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.

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