We are converting several branches from one bank to a second bank within our holding company. We have already mailed booklets explaining the change to affected customers, and the conversion will take place in about two weeks. Do you see any issues with a television commercial highlighting the branches as part of the second bank if it will start running before the conversion takes place?

No, we do not believe that running the television commercial before the conversion takes place will create any issues, particularly because the affected customers already have received notification of the branch changes.

We do recommend reviewing the Interagency Statement on Branch Names, which provides guidance for banks that are using one or more trade names for different branches of the same bank. While your institution is not using trade names, the same concerns addressed in the Interagency Statement — namely, customer confusion, particularly with regard to deposit insurance limits — also apply in this situation. We recommend training any frontline staff at the affected branches so that they are aware of the change and can explain it to your customers, including any deposit insurance coverage implications.

For resources related to our guidance, please see:

  • Interagency Statement on Branch Names (May 1, 1998) (“[T]he Agencies are concerned that if customers believe they are dealing with two different institutions, they may inadvertently exceed FDIC insurance limits by depositing excess amounts in different branches of the same institution. The Agencies believe it is important that customers understand the scope of FDIC insurance in these circumstances. Accordingly, an insured depository institution that intends to use a different name for a branch or other facility should take reasonable steps to ensure that customers will not become confused and believe that its facilities are separate institutions or that deposits in the different facilities are separately insured.”)