Our Web site folks are becoming frustrated with trying to determine when they need to display the FDIC logo, and when they need to give the Insurance disclosures. (Not FDIC insured, may loose value, etc). They want to create a sort of "template" that will appear on every page that will contain the Equal Housing Logo, the FDIC disclosure and the Insurance disclosures! I see a problem with this, and feel it could be not only misleading, but also in violation of law. Am I correct, or is there something out there that says we can have all three on every page? Thanks.

The web designers, web masters, and marketing people that I have dealt with or deal with are well-meaning people but are concerned primarily with the "appearance" of the page. That does not however negate the need for appropriate disclosures.

I am the Wealth Management Compliance Officer and what I did when our site was re-designed, was review each WM page on the site. I evaluated each page and determined the need for disclosure(s). On some pages we have as many as 5 or 6 different disclosures, but I don't have any that have both the "Member FDIC" and the "Not-Not-May".

I would first direct you to the Feb 15, 1994 Interagency Statement on Retail Sales of Nondeposit Investment Products - sorry I don't have a hyperlink for that reference.

Second, you want to avoid customer confusion. By putting both the Member FDIC and the "not-not-may" on the same page, you might run into a potential problem, if not from a customer, then possibly a regulator.

One compromise solution I came up with was to build disclosure table that contained all of my disclosures. I numbered them 1 through whatever. Then the web folks built a separate disclosure frame on the bottom of each page. I told them which disclosure numbers applied to that page and the web folks programed the disclosure number into the frame. Once that was done, the frame, pulled in the text automatically. A major benefit to doing it this way - when the wording on a disclosure changes, it now only needs to be changed once in the table and the change gets pulled in automatically to all pages that include that disclosure number.

Hope this helps and Good Luck!

12 CFR 328.3 tells you that you need to use the FDIC logo, Member FDIC or some other approved disclosure where your deposit products are advertised.

Banking bulletins have held that the home page (because it is where most people enter your site) is an advertisement and should have it. I would believe that because (generally) your pages may be bookmarked individually those advertising deposit products should have this disclosure.

NDIP pages, in my opinion, should be separated and not contain the FDIC disclosure. If your page is designed sufficiently to separate insured from non-insured, you could do this. This can be subjective however and is more of a hornets nest I'd avoid.

If you opt to have these together or to use frames in your site, make sure your disclosure shows properly in different screen resolutions. You'll see more at 1024x768 than you will at 800x600. Will the latter provide misintrepretation when the site is viewed? What about at 640x480? These are things your designer should be considering.

Also, if you use the logo, be sure the Webmaster uses ALT text as well. It is an easy step towards ADA compliance.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

Andy - you mention "make sure your disclosure shows properly in different screen resolutions. You'll see more at 1024x768 than you will at 800x600. Will the latter provide misintrepretation when the site is viewed? What about at 640x480? These are things your designer should be considering." We had someone tell us recently that they thought our disclosures were missing from our web pages when in fact they weren't, you just had to scroll down the page to see them. Do we have a concern about not seeing the entire page without having to scroll?

You need to be concerned how it appears and if the disclosure is noticeable or not. Is it obvious that the user needs to scroll down
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here to see it. Well, you get the point. You could argue that it is there and there is no clear and conspicious requirement. But why argue on that. Boast that you have the coverage.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

[This message has been edited by Andy Z (edited 03-13-2001).]

[This message has been edited by Andy Z (edited 03-13-2001).]