Back in December, the FDIC issued a Final Rule to amend Part 328 which addresses FDIC Official Signs, Advertisement of Membership, False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC’s Name or Logo. On July 16th, they also released 23 questions and answers related to these amendments. While some of this information is not necessarily new, there are a few nuggets we feel are worthy of your attention as you prepare for the January 1, 2025, mandatory compliance date.
- If your website is purely informational, with no ability to make deposits or access deposits, it is not considered a digital deposit-taking channel.
- As to the requirement to display the official digital sign near the top of a page/screen and near the bank's name, it does not need to be displayed every time the bank's name appears, such as in the footer of the webpage. Additionally, the official sign does not have to follow the user as they scroll up or down a page, if the image does not fit a particular device or screen (like a phone), the official digital sign can be scaled, “wrapped,” or “stacked” to fit.
- While there is no requirement for the non-deposit sign to be displayed near the top of a webpage or screen, including it only in a footer would generally not meet the clear, conspicuous, and continuous display requirement.
- If your bank has a deposit-taking ATM, and also offers non-deposit products, the new separation of signage rules apply, but you are not required to take down physical FDIC official signs attached to ATMs.
Be sure to check out our webinar, “FDIC Signs & Advertisement of Membership” which is available now OnDemand. These Q & As are a great supplement to the webinar as they help further clarify a few of the issues discussed during the webinar.
Published
2024/07/24