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.