We offer a rewards program where customers can earn points in connection with their checking account. The website where they can go to check their point balance has the bank logo on it. Do we need the member FDIC log on that site?

I'm torn because it has the bank name; however, the points are not FDIC insured.

Any thoughts are appreciated.

Thanks

As this from 328.3 reads"

"(c) Use of official advertising statement in advertisements--(1) General requirement. Except as provided in § 328.3(d), each insured depository institution shall include the official advertising statement prescribed in § 328.3(b) in all advertisements that either promote deposit products and services or promote non-specific banking products and services offered by the institution. For purposes of this § 328.3, an advertisement promotes non-specific banking products and services if it includes the name of the insured depository institution but does not list or describe particular products or services offered by the institution. An example of such an advertisement would be, "Anytown Bank, offering a full range of banking services."


I would place the logo on the other site. To me the argument is Why are people going to the site with the points balance? Because it is offered as a benefit of using a bank deposit product or service... in that case I would add the logo. Obviously the points aren't insured as that should be clear to any customer. However I don't think points (unless there is commentary the clears this up) are considered non-deposit products.... since they can't be offered as a stand alone product.

I think an argument could be made that it is a "hybrid product" but again... to me the real issue becomes what is the actual product, the points or the debit card? In the case you talk to your compliance consultants and they establish that it IS a hybrid product I would leave the logo off the website where the points total is located.

So sorry for a not that definitve answer but, IMO it isn't a hybrid product so I would put the logo on... but you have to establish whether it is or isn't a hybrid product for yourself.

Cheers!