Course description

The FDIC published a final rule on January 18, 2024, overhauling subpart A (Advertisement of Membership) of its Part 328 regulation and making some clarifying changes to Subpart B (False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC’s Name or Logo). Compliance with the revised regulation will be required starting January 1, 2025.

The 3” x 7” official FDIC signs that are familiar to bankers and their customers aren’t going away. But their placement may vary under the new rule and there are options that can be used in branches where deposits are accepted that don’t use the traditional teller window or station layout. Requirements for displaying non-deposit products signage have been clarified, as has the definition of non-deposit products.

For digital deposit taking channels, the FDIC has prescribed a new FDIC official digital sign and where it must appear. Also prescribed is a requirement for non-deposit signage when non-deposit products and deposit products are offered through the same digital deposit-taking channel.

New requirements will affect ATMs and similar devices (such as ITMs) that accept deposits. 

Finally, the revised regulation provides additional clarity in subpart B by revising certain definitions and the prohibited conduct provisions.

During the webinar, John will discuss:

  • Where the FDIC official sign must and must not be used
  • Options for placement of the FDIC official sign when non-deposit products are not offered
  • Variations on the FDIC official sign
  • Requirements for display of the non-deposit products sign
  • Use of electronic media to display required signs
  • Signs for ATMs and similar devices
    1. Machines in service before January 1, 2025
    2. Machines placed into service after January 1, 2025
  • Degraded or defaced physical official signs at ATMs and similar devices
  • Signs for digital deposit-taking channels
  • Official advertising statements
  • Required written policies and procedures
  • Clarifications in subpart B

 

WHO SHOULD ATTEND:

This webinar is for compliance personnel, auditors, individuals involved in branch design, marketing personnel, webpage and mobile app designers, and those involved in procurement of ATMs and similar equipment. 

Instructor(s)

John Burnett

John Burnett is a 1979 alumnus of the ABA National Compliance School, and served on its faculty for several years. He graduated with honors with the Class of 1990 from ABA's Stonier Graduate School of Banking, and is also a graduate of the BAIs and the Massachusetts Banker Associations Schools of Banking.John began his banking career in high school when he started as a teller at a $15 million bank that didn't have account numbers for its checking accounts (he says they actually filed by signature!) He joined Cape Cod Bank and Trust Company in 1971 and assumed the position of Compliance Officer in 1976. He also served as corporate secretary and secretary of CCBT's Board of Directors, as well as Clerk of the bank's holding company. John joined Glia Group, Inc. and the BankersOnline.com team in June, 2004. He is a frequent presenter of BOL Learning Connect webinars, and at BOL Conferences events.He was a member of the Massachusetts Bankers Association Legal and Regulatory Compliance Committee, and a former member of the American Bankers Association Compliance Executive Committee and NCS/NGCS Advisory Board. He served on ABA's Truth in Savings Task Force as Regulation DD was being written, and has served on several ABA and Massachusetts Bankers seminar panels.

Course curriculum

  • 1

    Update on the FDIC’s Revised Advertisement of Membership Rule

    • Watch Webinar

    • Handout

    • Slides

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