Another Delay to the FDIC Rule Changes
On March 3, 2025, the FDIC further delayed the compliance date for certain portions of its December 2023 Final Rule related to sign and advertising requirements.
Specifically, the requirements for ATMs and digital deposit-taking channels will now have a mandatory compliance date of March 1, 2026. The FDIC also indicated that it will be reviewing concerns related to both implementation and customer confusion and will likely propose changes to these requirements.
Institutions are still required to comply with the other changes found in Subpart A by May 1, 2025. These include:
- 328.3 Signs within an institution’s premises and offering of non-deposit products within institution premises;
- 328.6 Official advertising statement requirements;
- 328.7 Prohibition against receiving deposits at same teller station or window as noninsured institution; and,
- 328.8 Policies and procedures.
In light of this delay, the required policies and procedures do not need to address sign requirements for ATMs or digital deposit-taking channels until March 1, 2026.
Also, keep in mind, compliance with the changes to Subpart B (False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC’s Name or Logo) was mandatory back on January 1, 2025.
In light of this delay, we have updated our “FDIC Signage & Advertisement of Membership Checklist”. Version 1.2 is available now in the Free Deposit Tools on our website. Simply type “FDIC” in the search bar to find it quickly.
If you need training on these changes, be sure to check out our webinar, “FDIC Signs & Advertisement of Membership”, which is available now OnDemand.
Published
2025/03/05
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!