In your average day, I would guess you rarely think about FDIC signage. Sure, it comes up with advertising, but beyond that, is it ever top of mind? Because of that, it was easy to gloss over the effective date of a new rule on April 1. Before I get any further, let me ease any worries that the last sentence may have invoked. The mandatory compliance date is January 1, 2025, so if you glossed over it like many others, there is still time to correct it. The FDIC says that the “…extended compliance date is intended to provide sufficient time for financial institutions to put in place processes, systems and technological updates to implement the new regulatory requirements…”
Last December, the FDIC finalized amendments to its rules on official FDIC signage, bank advertisements, deposit insurance misrepresentations, and the misuse of the FDIC’s name or logos. The FDIC aims to modernize the rules for digital banking services through these amendments. Critical provisions for federally insured banks include:
- New FDIC Digital Signage: The amendments create a new official digital sign for the FDIC and address how banks must display it on ATMs and other remote deposit electronic facilities. They also establish a set of rules for the display of the new official digital sign in a bank’s “digital deposit-taking channels.” The regulations require the official digital sign to be continuously and conspicuously displayed on specific pages or screens in a bank’s digital deposit-taking channels.
- Modernizing FDIC signage on Physical Premises: The amendments modernize rules on displaying the FDIC official sign on physical premises where consumers have access to or transact with deposits beyond the traditional teller window.
- New Shorthand for the Official Advertising Statement: The rule changes permit banks to use “FDIC-Insured” in addition to “Member FDIC” as a shortened version of the official advertising statement, “Member of the Federal Deposit Insurance Corporation.” The complete or shortened versions of the official advertising statement must appear in certain bank advertisements.
- Separating Non-Deposit Products: The FDIC created new provisions to help consumers understand when a product is a deposit product covered by FDIC insurance and when a product is a “non-deposit” product. The amendments identify situations where banks may not offer deposit and non-deposit products near each other and when banks are permitted to provide deposit and non-deposit products in the same channel. The new rules require banks to provide certain disclosures regarding the non-deposit product.
- Policies and Procedures: Under the new rules, banks must establish and maintain written policies and procedures to address compliance with Part 328. Notably, the policies and procedures must include provisions related to monitoring and evaluating activities of certain third parties that provide deposit-related services to the bank or offer the bank’s deposit-related services to others.
You may find our summary of the rule useful. If you have any questions, please feel free to reach out to the Compliance Alliance hotline for assistance.