Thank you for the clarification. We will set aside the banner ad for a moment and address the collection of accredited CHE on a gated section of a corporate sponsored website first. It is important that this method of distribution / dissemination of the CHE meets the accrediting body’s regulations (possibly including approval by the body). Also, if there is any content in addition to the accreditor-approved library of manufacturer-sponsored CHE on the website, that website likely requires PAAB review. At the very least, the website framework should be reviewed.
With regards to the non-product branded banner ad, when understood that it meets the accrediting body’s regulations (possibly including approval by the body), it would not require PAAB review if the website did not require review. If there was any content in addition to the accreditor-approved library of manufacturer-sponsored CHE on the website, then the banner would be assessed as part of our review of the website framework.
This sort of scenario is multi-factorial. If there are additional factors you’d like us to consider regarding this initiative, please submit an advisory opinion.