FDIC Advertisement of Membership & Non-Deposit Products
On May 1, 2025, new requirements and restrictions took effect for FDIC-insured institutions that also offer non-deposit products. As a result, areas where insured deposits are typically accepted must be physically segregated from any areas where non-deposit products are offered or sold. There are a variety of ways to achieve this, including things like a separate room/office for non-deposit product activities; a partition or railing that separates deposit-taking areas from non-deposit product areas; configuring desks or cubicles in a way to separate these two areas, etc. There could be instances, however, where such physical segregation presents a challenge. The FDIC states, in its “Questions and Answers Related to the FDIC’s Part 328 Rule”:
For example, due to limited space, an IDI (insured depositary institution) that offers both deposit and non-deposit products in the same private office and at the same desk, may switch between displaying the FDIC official sign and non-deposit sign when discussing the relevant product to help minimize customer confusion. However, at no time should a non-deposit sign be displayed in close proximity to the FDIC official sign. (Physical Premises - Question #6) Keep in mind, the determination of whether an institution has justifiable space limitations will be subject to the discretion of its examiners.
Jerod explains more in the video.
2025/12/26
Jerod Moyer
Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru. Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports-related!