FDIC Updates Questions & Answers
The FDIC recently updated its Questions and Answers (Q&As) related to official signs and advertising requirements. Most of the changes were related to the official digital and non-deposit signage requirements. As you may recall, a revised Final Rule was issued back in January 2026, with a mandatory compliance date of April 1, 2027. There were, however, some other minor updates and additions to other areas as well and we’ve included a few below. Be sure to check out the June issue of Banking on BCC for our full article.
- Credit life and disability insurance are typically viewed ...as part of the offering of credit... and do not trigger non-deposit signage.
- For ATMs put into service after April 1, 2027, that allow access to non-deposit products, the official digital sign is required to be on the “initial screen”. The rule itself clarifies that a screen saver is not considered to be the initial screen but the FAQs expand on this further. The ...“initial screen” is the screen that is displayed before an IDI’s (insured depository institution) customer inserts a debit card or other credentials to access the device (sometimes referred to as a “welcome screen”).
- While the rule requires the official digital sign appear on specific pages of any digital deposit-taking channel, the official digital sign is not to be used in place of the official advertising statement on what the Q&As refer to as “advertising pages”. Advertising pages (i.e., commercial messages, in any medium, designed to attract public attention or patronage to a product or business) must adhere to the requirements of 12 CFR §328.6, which requires the inclusion of an official advertising statement, either “Member of the Federal Deposit Insurance Corporation,” or a short title of “Member of FDIC,” “Member FDIC,” “FDIC-insured,” or a reproduction of the FDIC’s symbol. IDIs are not required to display the official FDIC digital sign on advertising pages.
If you’d like to learn more about the Final Rule, be sure to check out our 30-minute flash webinar, “FDIC Official Digital and ATM Signage and Update”, which is available now OnDemand.
Published 2026/06/30
Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!
