Affiliate Marketing Rule Application to Information Obtained by the Credit Union

Question - Under the affiliate marketing rule, 12 C.F.R. §1022.20(b)(4)(ii)(D) allows solicitation for three months if a consumer applies for a product or service from a credit union but does not obtain it. Could we interpret this to mean that if someone applies for membership and does not follow through with completing all the necessary paperwork, we could market to them for three months using the information that they have provided?

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