Topic: Member FDIC Disclosure
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Our marketing brochure for the bank promotes our safe deposit boxes, among other services. The front of the brochure includes the “Member FDIC” disclosure. We were told that we should not include that disclosure when marketing nondeposit products. Should we remove the Member FDIC disclosure from the brochure?
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No. You are required to include the “Member FDIC” disclosure on the brochure. The FDIC requires you to use the Member FDIC disclosure when marketing both deposit and nondeposit products in an advertisement. In advertisements combining deposit and nondeposit products, you must “clearly segregate” the Member FDIC disclosure from information about the nondeposit products. In…
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Occasionally our bank will sponsor a non-profit’s fundraising event. The donation levels are printed in the event program with the bank’s logo, which includes the bankâs name. Is the event program considered to be advertising that would require the use of the “Member of FDIC” statement?
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Yes, it is likely that the event program would be considered to be advertising, triggering the requirement for the “Member of FDIC” statement. The FDIC Advertisement of Membership rules require the “Member of FDIC” or “Member FDIC” statement for certain types of advertisements. “Advertisement” is defined broadly as a commercial message that is designed to…
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Do we have to put the “Member FDIC” disclosure on every piece of marketing, even pens, pencils, etc.?
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The “Member FDIC” logo on advertisements is governed by 12 CFR 328.3. The general rule: “(c) Use of official advertising statement in advertisements —(1) General requirement. Except as provided in §328.3(d), each insured depository institution shall include the official advertising statement prescribed in §328.3(b) in all advertisements . . . .” Definition of “advertisement”: “(a)…