As you may know, the implementation of the FDIC’s changes to Subpart A of Part 328 (FDIC Officials Signs and Advertisement of Membership) has been a little chaotic. Some of the changes went into effect back on May 1, 2025, while the compliance date for others was delayed and then there were some changes re-proposed. It’s been a little crazy but, on January 22nd, we got the last piece of the puzzle as the FDIC announced a Final Rule for ATM signs (§328.4) and signs for digital deposit-taking channels (§328.5).
This Final Rule pushes the mandatory compliance date for §328.4 and §328.5 out to April 1, 2027.