Our bank is very close to making internet banking active for the general public. I was asked recently to enroll so that I could examine the site for potential Compliance issues.

Our internet banking product will, as is normally the case, be accessed from our bank website. I review the bank website quarterly for compliance and find no issues at present. However, I noticed that "Member FDIC" is nowhere on the internet banking site. I mentioned this to the Internet Banking (IB) team and stated that I had normally seen the FDIC membership reference somewhere next to or near the bank's name on each page on other internet banking sites I use. The IB team contacted our internet banking software vendor who stated that 1) they could not add this, 2) none of the other banks that they supply has asked for it nor have they ever had anyone question it, and 3) they were certain that the "Member FDIC" on the bank's website main page (which is where the sign-on for internet banking is) automatically takes care of this.

Trying to be proactive and protect my bank, I am concerned that the absence of the membership advertisement will come back and bite us.

I've looked high and low and can't seem to find any concrete reference showing the need for the membership advertisement on internet banking pages. (By-the-way, we have no NDIP or other references on the internet banking site which would hinder our use of the membership advertisment on any/all pages).

Common sense says that we should always use the membership advertisement unless contradicted. Any thoughts or helpful suggestions?

Thanks,

We are an FDIC regulated bank. We were told by our examiners that it had to be on each page due to each page being an advertisement. We did have it on every page except where we are hindered. The only criticism we received was due to not having the "Member FDIC" separate from the standard bottom of the page info - Legal Notices, Site Map, etc. We now have it on a separate line.

We have both the FDIC ant the "outhouse" on all of our webpages.
IMHO, they belong on any advertisement for deposits and loans, I consider the website an advertisement. You don't get in trouble if it's there, only if it's not there. Again, only MHO.

Ski-

Refer them to the FDIC guidance here - if you advertise deposit products on subsidiary - you must include the offical advertising statement (see the section on Bank Internet Sites).

FDIC Signage and Logo

Randy, thanks so much for the reference. In my zeal (and ranting), that's one site I had overlooked.

This is a great start!

Now the additional thought: If the internet banking vendor offers a DEMO sight and the bank's name/logo is on it, should the DEMO also have the membership advertisement?

If the DEMO site is available to the general public (or even a beta test group of customers), the answer is yes. Sounds like you may not be dealing with one of the more reputable banking website companies?? Who performed your due diligence, including the review of currently sponsored bank websites??

Just another thought..Within the internet banking section of a website, most banks don't "advertise" you're usually just presenting the customers information. In this case I believe the FDIC logo on the login screen should be sufficient. If you have the opportunity to advertise within the Internet Banking pages, then yes, I agree it would be appropriate.