State National Bank has a Web site on which it advertises all of its products. One page of the Web site is devoted to the products of its affiliate, State National
Investment Products, Inc. The affiliate sells uninsured mutual funds and various other investments not insured by the FDIC. What are State National's responsibilities for this advertising?
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A. B. C. D.D
State National Bank is responsible for the content of its website, including any advertising materials. The bank must ensure that any advertising material for its affiliate, State National Investment Products, Inc., complies with all applicable laws and regulations.
Option A, "None. The affiliate is responsible," is not entirely accurate because the bank is still responsible for ensuring that the affiliate's advertising materials comply with applicable laws and regulations.
Option B, "None. Because it is a Web site, the advertising rules do not apply," is incorrect. Advertising rules and regulations apply to all forms of advertising, including online advertising.
Option C, "The bank must make sure the FDIC logo is properly placed," is partially correct. While the bank must ensure that the FDIC logo is properly placed on its website, this requirement applies to the bank's own advertising materials, not those of its affiliate.
Option D, "The bank must make sure that the noninsured disclosures are on this page and that the FDIC logo does not appear," is the most accurate answer. The bank must ensure that any advertising materials for its affiliate clearly disclose that the products being offered are not insured by the FDIC. Additionally, the bank must ensure that the FDIC logo does not appear in any advertising materials for its affiliate, as this could be misleading to consumers.
In summary, the bank is responsible for ensuring that its website and any advertising materials for its affiliate comply with all applicable laws and regulations. This includes ensuring that noninsured disclosures are present and that the FDIC logo does not appear in any advertising materials for the affiliate.