Banking and Finance Law Daily Wrap Up, DEPOSIT INSURANCE—FAQs address new FDIC signage rules, (Aug 19, 2024)

By Lauren Bikoff, MLS

The FAQs provide clarifying information on the final rule, which must be fully implemented by Jan. 1, 2025.

The Federal Deposit Insurance Corporation (FDIC) has published a series of frequently asked questions (FAQs) relating to the 2023 final rule governing deposit insurance disclosure requirements for modern banking channels like online banking, ATMs, and bank cafes. The FDIC noted that the FAQs are a collection of questions and answers that the agency has received from stakeholders, including banks, trade associations, technology companies, vendors, and other entities.

Final rule. The December 2023 final rule modernizes the regulations governing the use of the official FDIC sign and advertising statements, as well as rules related to false advertising and misrepresentations regarding deposit insurance coverage, and the misuse of the FDIC’s name or logo (see Banking and Finance Law Daily , Jan. 2, 2024). The rule (12 C.F.R. Part 328) had not been updated since 2006 and did not address online banking, the FDIC noted. The final rule is intended to help consumers better understand when they are conducting business with an FDIC insured depository institution and when their funds are protected by the FDIC. The rule became effective on Apr. 1, 2024, and has a compliance date of Jan. 1, 2025.

FAQs. As the compliance date draws closer, the FDIC plans to update these FAQs as needed. The FAQs cover five main implementation topics: physical premises; digital channels (e.g., websites or apps); technical assistance; compliance and effective dates; and advertising for non-deposit products. For example, the FAQs address the placement and display of the official digital sign and non-deposit sign; the use of the advertising statement on various deposit-taking channels on websites, mobile apps, ATMs, and social media; and information on where to obtain downloadable versions of the official digital sign.

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