FDIC Signs “Within an Institution’s Premises”
If you haven’t had a chance to dig into the FDIC Rule changes just yet, this is your warning that they are likely a little more involved than you may think. Some may (and we think likely will) make your head spin.
First and foremost, it’s important to understand that the official FDIC sign will not be changing. It will remain a 7” by 3” sign with black lettering on a gold background. These changes do, however, allow and, in some cases, require different signs for deposit-taking areas within an institution, as opposed to ATMs which are outside the institution, as well as even different requirements for “digital deposit-taking channels”. What applies or is allowed for one is not necessarily the same as the others.
One interesting change is that, while the official FDIC sign has not changed, the Rule does allow signs displayed within the financial institution to have slight differences. It states:
An insured depository institution may display signs that vary from the official sign in size, color, or material at any location where display of the official sign is required or permitted…However, any such varied sign that is displayed in locations where display of the official sign is required must not be smaller in size than the official sign, must have the same color for the text and graphics, and include the same content.
We believe this means that while you may be able to play with the gold background, the text and graphics need to appear as they do in the official FDIC sign, using the same black font. We wouldn’t play games here by getting overly creative and do highly recommend ordering signs directly from the FDIC.
This is just one consideration for “on premises” signs and we will discuss this more in our June edition of Banking on BCC.
We have put together a checklist of key things/areas to consider as you begin to work towards implementing these changes. It is available now in our Free Deposit Operations Downloads. Keep in mind; this is not a substitute for training. There are a lot of intricacies within this Rule, and it would be difficult to include everything while still aiming to keep the checklist short and user-friendly.
We encourage you to check out our webinar, “FDIC Signs & Advertisement of Membership”, which is available now OnDemand.
The mandatory compliance date for this Rule is January 1, 2025.
Published
2024/05/14
Diane Dean
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients. Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!