FDIC Updates Signs and Advertising Q & As
On December 2, 2024, the FDIC released additional Q & As related to the Official Signs & Advertising of Membership Requirements (Subpart A of Part 328) which take effect on May 1, 2025. There were a couple that we wanted to touch on.
- The first has to do with credit life and disability insurance and whether it is considered a “non-deposit product” that would be subject to the signage requirements. The FDIC’s answer states that, if credit life and disability insurance is offered in connection with a loan, it is a loan product and not a non-deposit product. So, if a loan officer offers credit life and disability insurance in their office in connection with a loan, the non-deposit product signage is not needed. If, however, that loan officer also offers other products that are considered to be non-deposit products, they would need to display the non-deposit product signage.
- The second has to do with whether someone can periodically use the same space or office to offer non-deposit products where deposit products are also offered, due to physical space limitations within a small branch. The FDIC has stated that, when space is limited, the FDIC insurance signage can be put up when offering deposit products and the non-deposit product signage can be put up when offering non-deposit products. Keep in mind that these two different types of signage should never be displayed at the same time.
Jerod explains more in the video:
Published
2025/01/14
Jerod Moyer
Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru. Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports-related!