The head of our marketing department sent me a competitors ad which had the following at the bottom of the ad:

BANKING INSURANCE INVESTMENTS

Member FDIC. Only deposit products are FDIC insured.

The ad itself was a generic ad about how good they are with no trigger terms. There was no not, not, may language included. Has anyone else ever used this shortened disclosure?

This is an example of what not to do.

Please define a deposit product. I send money into my mutual fund that I got from the nice lady at the bank, that is a deposit...right???

^^^^^^^^^^^^^^^^^What Bob said.

This bank is pushing the boundry for their next exam if this ad is seen.

Those were my thoughts exactly. The ad was in a magazine and was for a large bank. Marketing sent it to say "see, the other bank is doing it."

Tell your marketing department: "Other bank's actions do not exemplify compliance."

"Other bank's actions do not exemplify compliance."

I just love this response. I have a new mantra. Thanks Bob!

So what would be correct? Should the ad also include the Not/Not/May wording? or include neither Member FDIC nor Not/Not/May?

343.40(d) states Not/Not/May does not need to be included when advertisements and promotional materials are of a general nature describing or listing the services or products offered by the bank. But it seems deceiving to have to include "Member FDIC" when insurance is mentioned.

Bump

I have the same question as Carolina Blue. If all you have in the ad is the banks name,the investment department name and the insurance department name and they are separated in the ad. The address and phone number is under each name. You do not list any products, do you need the Not, Not, May disclosure under the investment section?