Answer by Randy Carey: Typically, these notices do not normally meet the definition of advertisement.
Sec. 328.3 Official advertising statement requirements.
(a) Advertisement defined. The term â€œadvertisement,â€ 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.
Answer by Andy Zavoina: The answer is no unless you are advertising another insured deposit product in that mailing. For this notice the customer already has the account with you and the insurance has been disclosed to them already. As Randy said, this is not an advertisement, it is not a new product.