The FDIC published a final rule on January 18, 2024, overhauling subpart A (Advertisement of Membership) of its Part 328 regulation and making some clarifying changes to Subpart B (False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC’s Name or Logo). Compliance with the revised regulation will be required starting January 1, 2025.
The 3” x 7” official FDIC signs that are familiar to bankers and their customers aren’t going away. But their placement may vary under the new rule and there are options that can be used in branches where deposits are accepted that don’t use the traditional teller window or station layout. Requirements for displaying non-deposit products signage have been clarified, as has the definition of non-deposit products.
For digital deposit taking channels, the FDIC has prescribed a new FDIC official digital sign and where it must appear. Also prescribed is a requirement for non-deposit signage when non-deposit products and deposit products are offered through the same digital deposit-taking channel.
New requirements will affect ATMs and similar devices (such as ITMs) that accept deposits.
Finally, the revised regulation provides additional clarity in subpart B by revising certain definitions and the prohibited conduct provisions.
During the webinar, John will discuss:
- Where the FDIC official sign must and must not be used
- Options for placement of the FDIC official sign when non-deposit products are not offered
- Variations on the FDIC official sign
- Requirements for display of the non-deposit products sign
- Use of electronic media to display required signs
- Signs for ATMs and similar devices
- Machines in service before January 1, 2025
- Machines placed into service after January 1, 2025
- Degraded or defaced physical official signs at ATMs and similar devices
- Signs for digital deposit-taking channels
- Official advertising statements
- Required written policies and procedures
- Clarifications in subpart B