My bank is putting in a "congratulations" note and a donation to a local high school. This note will indicate the bank's name and be included in as a sponsor in the Program Book for the ceremony. I do not believe we need to include the Equal Housing Lender and FDIC notices under the bank's name as this is not an advertisement. Am I correct?

If it is not advertising anything specific, I would agree with your assessment. Even more so if you offer non-deposit products too... consider the "letterhead or envelope" example.

Cheers!

Thanks. What do you mean byLetter head or envelope example?

See 12 CFR 328.3, FDIC signage requirements: Insured banks to include official advertising statement in all advertisements except: ...Bank supplies such as stationery (except when used for circular letters), envelopes, deposit slips, checks, drafts, signature cards, deposit passbooks, certificates of deposit, etc.;...

This section of the regulation also calls out "listings in directories" as an exception not requiring the Member FDIC notice. This high school program might qualify as a directory. If our name was shown in a program in a list along with the names of other individuals/entities, we would not include Member FDIC. However, if we had a small block with our logo, we would include Member FDIC.