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Do we need to post the FDIC official sign on our night deposit boxes that are on the outside wall of our branches? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Do we need to post the FDIC official sign on our night deposit boxes that are on the outside wall of our branches?

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No, you are not required to post the official FDIC sign on night deposit boxes. An FDIC Advisory Opinion states: “FDIC regulations do not specifically reference night depositories, but FDIC staff has generally taken the view that deposits are not ‘received’ by the bank when the deposits are placed in a night depository; hence, no sign is required.”

For resources related to our guidance, please see below:

  • Advisory Opinion, FDIC 94-17 — Night Depositories and Official Bank Signs (March 28, 1994) 
  • 12 CFR 328.2(a) (FDIC official sign requirement)