Are there any compliance requirements when advertising an ID Theft prevention program?

Well, based on some recent enforcement actions, I would say you want to be very clear what the program actually does.

If the customer does not pay for the ID Theft Prevention product and it is a free feature of the deposit account, are you required to have the Non Deposit Investment Product disclosure in your advertising?

On this same topic, ID Theft Prevention product, how do you relate it to your privacy notice? The bank partners with the company and signs up the customer, the vendor then contacts the customer and the customer goes to their website and enrolls and gives their personal details and the vendor delivers the service. The bank account facilitates the billing source, but I think they can change their billing method.

Are we joint marketing or are they a non-affiliated third party? I looked at several banks websites that have the same ID theft protection product, and none of them said the bank joint markets or shares with nonaffiliates on the privacy notice on the website.

We do not sign up the customer or provide the company with any information. We give the customer a logon ID and they go to the website and sign up if interested. So, we don't reflect it on our privacy notice.

There is not charge for this product to our customers and there is no up-selling on the company website.