Answer:
Even without listing products and services it is an advertisement according to the FDIC membership rules. "(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." You state that the intention is to draw attention to your new location so you will need to include the required FDIC logo/statement within the invitation/brochure. (12 CFR 328.3)
First published on BankersOnline.com 1/19/09
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