Late last year, the Federal Deposit Insurance Corporation (“FDIC”) announced that it had adopted a Final Rule designed “to modernize the rules governing use of the official FDIC signs and advertising statements, and to clarify the FDIC’s regulations regarding false advertising, misrepresentations of deposit insurance coverage, and misuse of the FDIC’s name or logo.” The Final Rule included adoption of a new black and navy-blue FDIC official digital sign, which banks will be required to display on their websites, mobile applications, and certain ATMs. A summary of the Final Rule—called the Official Signs and Advertising Requirements, False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC’s Name or Logo Final Rule and located at 12 CFR part 328— can be found here.

Recently, the FDIC published an online Q&A that can assist in understanding nuances of the Final Rule, including what is required and how. The Q&A covers both physical signage (e.g. at a bank’s new accounts desk) and digital signage (e.g. on a bank’s website, app, or ATM). The Q&A also confirms the following regarding compliance: “The compliance date for the amendments made to the final rule is January 1, 2025. No changes had to be implemented by April 1, 2024, but IDIs can begin posting the official digital sign and implementing other aspects of the regulation prior to January 1, 2025. For example, some IDIs have already posted the new official digital sign on their websites. Similarly, some non-bank entities have updated their disclosures consistent with the amendments to part 328 subpart B.”

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