Topic: Bank Signage
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The proposed Illinois Community Reinvestment Act (Illinois CRA) rules rewrite the language that must be included on Illinois CRA signage required to be posted at our main locations and branches. Are we required to use this new language now?
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No, the new language for Illinois CRA signage in the proposed Illinois CRA rules is not currently required, as the proposed rules have not been finalized. Additionally, the IDFPR may rewrite the required language when the agency finalizes the Illinois CRA rules. However, your bank should be posting the current version of the Illinois CRA…
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Do our “Member FDIC” signs need to use black letters on a gold background? When ordering signs, the option of white letters on black was offered.
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We believe that “Member FDIC” signs displayed in required locations may vary the colors of the text and background, provided that customers can still recognize the sign. The official FDIC sign, as described in the FDIC’s regulations, includes “black lettering and gold background.” However, “an insured depository institution may display signs that vary from the…
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What disclosures are we required to make available on our bank’s website?
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Below is a non-exhaustive list of the disclosures and notices that you may choose to post or may be required to post on your bank’s website. This list may be incomplete depending on the products and services you offer or advertise on your website, some of which may trigger additional disclosure requirements. Privacy Notices The…
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A mortgage loan originator (MLO) at our bank would like to post a flyer on social media advertising a residential mortgage loan program for physicians. The flyer contains both the MLO’s Nationwide Mortgage Licensing System (NMLS) identifier and our bank’s NMLS identifier. Does this information need to be listed directly after the message describing the loan program, or is it sufficient under Illinois law for these items to appear anywhere on the flyer?
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We do not believe you are required to include either NMLS identifier on the flyer, but you may include them if you wish to do so. The federal Secure and Fair Enforcement for Mortgage Licensing Act (SAFE Act)’s regulations require an MLO to “provide his or her unique identifier to a consumer: (1) Upon request;…
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A mortgage loan originator (MLO) at our bank would like to post a flyer on social media advertising a residential mortgage loan program for physicians. The flyer contains both the MLO’s Nationwide Mortgage Licensing System (NMLS) identifier and our bank’s NMLS identifier. Does this information need to be listed directly after the message describing the loan program, or is it sufficient under Illinois law for these items to appear anywhere on the flyer?
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We do not believe you are required to include either NMLS identifier on the flyer, but you may include them if you wish to do so. The federal Secure and Fair Enforcement for Mortgage Licensing Act (SAFE Act)’s regulations require an MLO to “provide his or her unique identifier to a consumer: (1) Upon request;…
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Does the Illinois Electronic Fund Transfer Act (EFTA) require that the logos of the ATM networks we participate in be included on our ATMs?
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No, we do not believe that the Illinois EFTA requires you to place the logos of the networks you participate in on your ATMs, provided that you are in compliance with the federal EFTA requirements. However, the networks themselves may require such signage as part of your agreements with them. The Illinois EFTA contains a…
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Is there an Illinois law requiring signage on ATMs regarding the networks in which a bank participates? If so, what are the requirements?
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We are not aware of any Illinois law or regulation requiring signage on ATMs indicating the networks in which a bank participates. However, the networks themselves may require such signage as part of your agreement with them. For example, the Mastercard Rules provide that the “Mastercard, Maestro, and Cirrus Marks must be displayed on an…
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We are aware that the IDFPR issued a Supervisory Statement regarding the Illinois Community Reinvestment Act (CRA) that includes revised language for the public notice requirement. May we still use the public notice language in the Illinois CRA to avoid purchasing additional signage later?
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Yes, we believe you may post a public notice containing the language set forth in Section 35-20 of the Illinois CRA. While the IDFPR’s Supervisory Statement indicates that it will consider the revised language referenced in the statement to be “substantially similar” to the notice provided in the statute, it does not require covered financial…
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Can we post a summary of our privacy policy in our lobby or should we post our current privacy notice in full to fulfill our signage requirements?
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We are not aware of a requirement in Illinois or federal law to post signage containing your privacy policy in bank lobbies. While you are required to provide adequate notice of your customer identification program (CIP), which many banks fulfill by posting a CIP notice in their lobbies, the privacy requirements in Regulation P do…
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We installed new security cameras in our branches that record both video and audio, rather than just video. Do we need to post a sign or notice alerting those who enter our branches about the recordings? Is there an Illinois law that requires such notice when recording devices are used?
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We are not aware of a requirement that banks post signage alerting customers that security cameras may be recording them, but we believe that some businesses may post such signs as a precaution in Illinois to avoid any possibility of criminal eavesdropping. Illinois’s criminal eavesdropping law prohibits persons from surreptitiously recording private conversations without the…