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We are opening a new branch and have limited room on the outdoor sign that will identify the branch. On the sign, can we shorten our bank name by removing one word – using “XYZ Bank” instead of our full name, which is “XYZ Community Bank”?

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Yes, we believe that you may display a shortened (but still identifiable) version of your bank name on an outdoor sign. In our view, omitting the word “Community” from the bank name should not create customer confusion. 

State and federal guidances require reasonable steps to avoid customer confusion when a bank uses a name other than its charter name. Particularly, bank regulatory agencies are concerned that customers may be misled into believing that different branches are actually separate entities or that deposits in different branches are separately insured. In this case, omitting the word “Community” from your bank name should not cause the type of confusion addressed by the agencies.

For resources related to our guidance, please see:

  • FDIC Advisory Opinion, FDIC-96-7 (March 8, 1996) (“The FDIC will not object to an insured institution using a different name for one or more of its branches, so long as the insured institution can demonstrate that it has taken measures reasonably calculated to ensure that customers will not be misled into believing that the two facilities are separate entities or that deposits in the two branches are separately insured.”) The FDIC has informed the IBA that it has removed all of its advisory opinions from its website due to a high risk of staleness. We have provided links to archived versions of the advisory opinions for your convenience. If you have a question about an advisory opinion, the FDIC recommends that you contact your FDIC Field Office, which you can find by clicking here.

  • Interagency Statement on Branch Names (May 1, 1998) (Specifies procedures that a financial institution should use to minimize customer confusion when it uses different names at different branches, including clearly and conspicuously disclosing in signs and advertising the facility is a branch of the insured institution, using the legal name of the insured institution for legal and customer documents, educating staff regarding the possibility of customer confusion, and obtaining signed statements from new customers that the branch is part of one insured institution.)

  • IDFPR Policy Statement on Branch Names (July 8, 1999) (Adopts the Interagency Statement on Branch Names)