IBA Compliance Connection

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For purposes of Regulation DD’s advertising requirements, is an outdoor electronic sign that is located on the bank’s premises (but not attached to the bank) a billboard? Or is it considered to be an indoor sign?

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An outdoor electronic sign would be considered to be “outdoor media,” such as a “billboard,” under Regulation DD. It would not be considered to be an indoor sign. Regulation DD states that “indoor signs” include any signs or advertisements inside the bank premises, and the rule provides examples of computer screens, banners, preprinted posters, and chalk or peg boards.

For resources related to our guidance, please see below:

  • Regulation DD, 12 CFR 1030.8(e)(1)(ii) (exemption from certain advertising requirements for advertisements made through outdoor media, such as billboards)
  • Regulation DD, 12 CFR 1030.8(e)(2) (signs inside the premises of a depository institution are not subject to certain advertisement requirements) and Official Interpretations, 12 CFR 1030, Paragraph 8(e)(2)(i), Comment 1 (“indoor signs include advertisements displayed on computer screens, banners, preprinted posters, and chalk or peg boards”)