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