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Our marketing officer would like to put an ad (for lack of a better word) on a benefits card for our Chamber of Commerce (all Chamber members get the card and it offers deals from local businesses). There is a local bank in town that currently has one on there that offers a gift card at account opening but has none of the required disclosures on it. Our marketing officer wants to do the same thing but I don’t see how we can do this without the proper disclosures which would be too much and wouldn’t fit in the tiny space allowed on the card. Is there some exemption I’m missing for ads of this sort? Another bank is offering free checks at account opening, wouldn’t this also trigger disclosures as a bonus?
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