Question: We are going to participate in charity event. Our employees will be wearing T-shirts with the bank's name and the name of the charity. We also plan to give away T-shirts. Is this considered an advertisement? Will we need to put the FDIC logo on the shirts?
Answer by John Burnett: You are clearly promoting the bank with the shirts, so they are ads. If your intent is not to promote the bank, why bother putting the bank name on the shirts?
You never have to use the FDIC's logo or symbol in an ad, but you are required to have, at a minimum, "Member FDIC" appear in the ad, somewhere. Put it in small print, if you want, but include it. I'd consider it a low risk violation if you've already ordered the shirts without the mention of the FDIC.
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