I would like some opinions, if I may, about signage.

We have the small (3" x 7") FDIC signs at the new accounts desks and all teller stations as required, but I'm wondering about one "unique" area in our facilities.

Our Trust and Investment department, our broker, our Private Banking department and our CEO all share a large office suite on the third (top) floor of our building. If someone in the Private Banking department opens new accounts at their desk (from time to time, they have other duties and are not devoted to new accounts), should I make sure that there is a FDIC sign on that person's desk? I'm hesitant because of the existance of offices that sell non-FDIC insured products that are in that proximity. If I can't have an FDIC sign at the desk of the person who will occasionally open new accounts, should I ask that they open the account elsewhere in the bank? OR What if a loan officer occasionally (OK, once every ten years) opens a new account at her desk? Does she have to have the sign on her desk? Should I simply ask them to put the sign in a drawer until they open an account, then put the sign up when they are finished?

You should have the FDIC sign where deposits are accepted. You also have to worry about the sign/no-sign scenario when NDIPs are sold. In your exec areas, what is the likelihood that they'll actually switch them out as needed, and which do they do more, deposits or NDIPs? Default to the most common.

I would provide the signage and the training on what is used when. I would update that training periodically, especially before an exam, if you know what I mean.

It would be best to put FDIC signs where the new accounts are opened and then ask the employee to move to a different desk for non-FDIC products. Or they could move to a different desk to open the FDIC products. I doubt they will pull out/ put away signs when needed.

Thank you Andy and David. I pretty much don't have to worry about this person doing anything with the NDIPs, but I will make absolute certain that she knows the drill.

We're facing the same (well sort of) issue right now. Branch is selling NDIP's and deposit products in same area. Mostly NDIP's. So last audit I did, I mentioned the need for FDIC signs when deposit products sold. The 3rd party firm audit also identified a problem with signage in this area. So the Bank representative decided to remove ALL signage in the area. If that's not bad enough, we're currently undergoing Safety and Soundness exam. The person that decided to remove all signage made sure to tell the examiner she was speaking with( By phone!).

After you publicly execute the first employee doing this, repeat violations are rare.

This isn't my area of expertise, but I will share with you how one of the smartest women in compliance I've ever known (I love ya Chris) handled the situation at Bank of America.

I sold both Non-FDIC and FDIC products at my desk (private banker). This was also the case for all top tier bank officers in branches. We removed the small FDIC sticker from our desks, and left them at the desks of the people who only opened FDIC insured deposits. This idea went through a through legal review after we found that hoping from signed desk to non-signed desk was just too burdensom for clients. (Picture it, yes Mrs. Smith I can open your checking account and link it to a Non-FDIC insured money market for your stock purchases. Fill out this paper work here...now we hop over to the "Non" bank desk and fill out some more paperwork...Oh you want a credit card too? Hop on back to the FDIC insured desk with me and we can talk about it...Mutual funds...dear god, pick up your stuff, we're back to the "non" bank desk). (Yes it happened ALOT! Darned clients won't stay with the right type of products in the order most convenient for sales people if ya tie strings around their fingers and poke em with sticks)

At the FDIC insured desks, no rates for Money Market accounts could be discussed, nor could fees for Non-FDIC insured products. That was easy because this information was only available to the licensed staff. We were audited regularly to see if we were using the correct verbage to disclose when selling, and yes, we had a "Non-FDIC" sign on our desk just in case we brought up those products. When the transaction was complete, we took the client up, introduced them to the head teller and the "deposit" was taken at her station, which was also signed FDIC.

Does that work? Did for us. And though I gained 10lbs after losing the exercise from running back and forth between my two desks, it was worth it. Nothing worse than a client who wanted a checking account, money market and was packing a kid and a diaper bag from desk to desk!

Thanks for sharing. Even the examiners currently here commented about how comical switching signs could be!

We started out with the desk swaps, moved to sign swaps (even had two business cards...you had to get your bank card back if you talked about Non-FDIC and give the investment business card which resulted in some funny tug of wars).

The change in signage was the way to go. Too much "Non-FDIC" signage isn't normally an issue as it's overdisclosure not nondisclosure (except when it encrouches in the teller area). Being early in the bank investment mix was fun and gave me some great stories to tell to the new kids on the block!

We just started selling non-fdic products here. When desk hopping came up I had the room in stitches with my live version of the last post

I am seeing more banks add the phrase, "Investment Products" above the box that contains the three magic phrases: "Not FDIC Insured" "No Bank Guarantee" and "May Lose Value" to more clearly differentiate between insured and non-insured.

I heard at a seminar that you only need to have the FDIC sign at locations where "deposits are recieved" ... meaning where they are receipted. So if a bank employee at the new accounts desk takes the deposit to the teller line to be receipted and brings the receipt back to the customer at the desk, they do not need to have the FDIC sign posted at the new accounts desk. Since the deposit wasn't receipted at the new accounts desk, it wasn't considered "received" at the new accounts desk for FDIC sign purposes. Does this sound correct? Thanks.

No, this doesn't sound correct. The bank received the deposit when the new accounts person took the deposit.

I believe someone created a rule of thumb which could in error for many of us. "receipted" is not a good rule if you accept deposits in one place and walk them to another.

Signage should be displayed at each station or window (incl. drop boxes, teller windows, New Accounts, drive-ups) where insured deposits are normally received, excluding automated service facilities such as ATMs, night depositories and POS.

Signs must be 3"X7" in size. Refer to 12 CFR 328.2 & FDIC 93-42, 94-17.

Another side of the question...what if at your new accounts desk insurance products are sold? Do you still want the FDIC signs? Many banks have multi-tasks performed by the new acccounts position.

The CPBSI rules require you to separate insurance sales from deposit taking activities. {See the FDIC's §343.50(a)]

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If an area is shared because of some acceptable reason, the signs would have to be changed just as the employee changes hats.

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Please excuse my levity at this late hour, but the above scenario brings to mind either a very good Monty Python skit - or a very bad SNL skit.

Quote:

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If an area is shared because of some acceptable reason, the signs would have to be changed just as the employee changes hats.


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Please excuse my levity at this late hour, but the above scenario brings to mind either a very good Monty Python skit - or a very bad SNL skit

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It actually is pretty funny to watch. BofA did this with licensed investment people. I had two desks next to each other and a seperate business card for investment sales and bank item sales. If you sat at my desk to talk about checking accounts all was well...but god forbid if you wanted a sweep into a mutual fund....haul on your coat, pick up your gloves, purse and babies...we're going back to the investment desk. (a card for investments is then handed out as I yank the bank business card from your hand)

Oh dear a loan....Pick it all up baby and head back to banker land desk....(yanking the business card back from your hands as you rise...)

Annuity? Retirement? E gads how about free checking and a balloon!

It was a nightmare for those first few months til they removed the FDIC signs from our desks and just let us sing disclosures til our voices cracked!

Can you send us the video. I'd like to see that!

We have only recently started selling annuities at this bank. At the bank I was with before, only designated persons sold these so there was no problem. Here we have the branch people selling. I was just in the branch and they had the annuity signs on their credenzas behind the desk and the FDIC on the desk. They said they were told to put them on the back, off the desk and they were ok and didn't have to bother with switching the signs. Fix one thing then there's another.

Personally I think the desk hopping should be a requirement for all sales people. It was a hoot! I used to watch the people in the branch giggle while I moved back and forth....LOL you sure learn to steer a conversation to the right product for the desk you're at quickly! (Well until the evil compliance folks figured out the sign issue as well) LOL

If you have the customer sign an acknowlegdement with each application for an NDIP which stresses that the product they are applying for is not FDIC insured, is it necessary to remove the "Member FDIC" sign from the desk also?

I would say YES. Otherwise it could be confusing to the customer, present them with the wrong message initially and it just isn't good to send mixed messages.

Speaking of mixed messages, our securities person has an office down the hall from the bank office. He has placed signs in the bank "advertising" annuities. The signage has the proper disclosures, "not FDIC insured" etc., but our internal auditors are telling him to take the signs down because it could be too confusing to the consumer. I'm not sure I agree because the signage is clear and the bank employees know they would have to refer the person to the securities area and the securities person is supposed to inform the customer about the products. Would anyone agree/disagree? Thank you.

The Member FDIC rules for adverdising and the requirements for nondeposit investements is starting to confuse me and I need some help in determining how to handle a new situation.

In our Customer Service Reps. offices we have a large poster on the wall that lists products and services that we have. For example Free Checking and ebanking. We also have the bank logo on the poster and under the logo we have Member FDIC (very small print). On the CSRs desk we also have a small display of this poster with a handout (all the informtion is the same as the poster). All that is OK except we now have annunity posters on the CSRs desks with the required disclosure information for nondeposit products. Is it wrong to have this information together? Do we need to get the Member FDIC off of the poster, etc. in order to have all in the same office? If we take it off, is that a violation under FDIC?

D,
If I read your post correctly, your poster does not contain an advertisement for the annuity, it is contained on a seperate notice but on the same desk right? As long as you are not mixing FDIC insured deposit products with Investment products you are okay. You just cannot have an investment advertisement of any kind that eludes to being FDIC insured. This is for advertising purposes only.

Now if your CSRs are transacting business in relation to the NDIPs, then I would refer to all of the above posts. To me it sounds like you are just making them aware that they can visit with your investment manager, right?

The CSRs can sell annunities at their desks.