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#1690082 - 04/18/12 07:21 PM FDIC signage
markp Offline
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New Jersey
From 328.3
Signs or plates in the insured depository institution offices or attached to the building or buildings in which such offices are located;

What does it mean by (in the insured depository offices)? Is this referring to inside the bank and not what sits on the land? If so would this include a thank you sign with our logo on it that our customers see when they are exiting the drive thru that is not attached to the building?

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General Discussion
#1690207 - 04/18/12 10:36 PM Re: FDIC signage markp
BBoyd Offline
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BBoyd
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Posts: 2,494
MI
It says "IN the offices...or attached to the BUILDINGS in which such offices are located." Seems the sign is not IN the office or ON a building, so the FDIC logo wouldn't need to be on it. It should, however, be on display at the drive thru window.
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#1690274 - 04/19/12 01:22 PM Re: FDIC signage markp
John Burnett Offline
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Cape Cod
Actually, the language markp has quoted from the regulation describes an exemption from the requirement. The sign markp askes about doesn't fit that description, so, if it is an advertisement, it needs "Member FDIC."

Personally, I don't consider "Thank you" an ad. It's just a nice courtesy, even if it includes the name of the bank. I don't think that "Member FDIC" is needed.
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#1690324 - 04/19/12 02:10 PM Re: FDIC signage markp
Bob The Banker Offline
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Furthermore, does your logo contain your bank's name? If not then it would be exempt from that perspective.

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#1690469 - 04/19/12 04:38 PM Re: FDIC signage John Burnett
markp Offline
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Posts: 382
New Jersey
Originally Posted By: John Burnett
Actually, the language markp has quoted from the regulation describes an exemption from the requirement. The sign markp askes about doesn't fit that description, so, if it is an advertisement, it needs "Member FDIC."

Personally, I don't consider "Thank you" an ad. It's just a nice courtesy, even if it includes the name of the bank. I don't think that "Member FDIC" is needed.


Thanks John, Our consultants said we needed to the FDIC on that particular sign. If we put it on that sign we would need to put it on the sign that sits out by the highway with our name on it, the only different from our raod sign is this sign says thank you for your business and has our website on it with a phone number.
Last edited by markp; 04/19/12 04:45 PM.
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#1690561 - 04/19/12 06:57 PM Re: FDIC signage markp
John Burnett Offline
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John Burnett
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Cape Cod
When you add the website and phone number, you are inviting a return trip, real, virtual or telephonic. That's an ad.

When things aren't reduced to specifics, reasonable minds can disagree, and I disagree with your consultant on the "Thank you" sign. But you didn't pay for my opinion, and I respect the fact that the consultant is taking a more conservative approach. Fact is, I can guarantee you won't get dinged by the FDIC for including the "Member FDIC" on the sign.
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#1690653 - 04/19/12 08:31 PM Re: FDIC signage John Burnett
markp Offline
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Posts: 382
New Jersey
Thanks John, your right, it is the safest action, we have our website on our main sign by the road, do we need to have the FDIC on that as well?
Last edited by markp; 04/19/12 08:46 PM.
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#1691070 - 04/20/12 04:43 PM Re: FDIC signage markp
John Burnett Offline
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John Burnett
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Cape Cod
With or without your website on that sign, it can be considered advertising (Looking for XYZ Bank? Here we are! Come on in!), Otherwise, why bother with the fancy expensive sign? Member FDIC ought to be on it.

Perspective -- I have NEVER heard of a bank getting dinged by the FDIC for leaving the "magic phrase" off of these types of signs, and I see hundreds of them without the phrase. In honesty, I think the FDIC focuses on the more obvious things, such as whether you have the right size, shape and version of its official sign at the required spots in your offices, whether you include (or exclude) the "magic phrase" from certain web pages, brochures, and obvious ads.
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