We have a home improvement loan that some realtors want to tell their clients about. The flyer would be created by the bank and include the loan program information, the bank's contact information and the realtor's logo. There will be no referral fee paid and we are documenting this arrangement in an agreement. The bank is not sharing any client information with the realtor, and the realtor wouldn't share their client information with the bank. If the client is interested in the loan, they would contact the bank directly.

Does this arrangement need to be disclosed on the bank's Privacy Notice under Joint Marketing?

Since the bank is creating the ad, we will bear the cost of that, also any printing of hard copies. If the realtor company emails the flyer to their agents, how do we bear the cost of the agents printing the flyers? If the flyer is emailed instead of printing, how do we measure that cost?

What does a realtor have to do with home improvement loans? If you are putting their logo on the flyer, then it is joint advertising, and you need to split the costs, whether that includes distribution or design costs. I fail to see a real connection between realtors and home improvement.

The realtors think having this loan available will help sell more homes that may need a little TLC.

What about the Privacy Notice? Does this relationship need to be disclosed?

You are not sharing any customer information, so no. You are not marketing a "joint product".

I don't see how the realtor is benefitting by promoting your bank, when there are likely 100's of banks that offer the same loan? Are you in turn advertising the relator?