Is there a problem with combining the FDIC Signage required to be posted at each teller station with other required signage such as Funds Availability, CIP, etc.? These would be all on one form and the thought is to get the clear plastic frames that you can attach to something (not stand up frames).

As long as the membership sign is the official sign, i.e., size, color, etc. Having that sign with others disclosures would not be prohibited as long as it is properly posted.

https://www.bankersonline.com/regulations/12-328-001
https://www.bankersonline.com/regulations/12-328-002

I suggest you compare their placement requirements. If you do not open new accounts at the teller window, the CIP notice does not need to be there. Also, despite what the forms vendors say, the Regulation CC Commentary clearly says:

Such notice need not be posted at each teller window, but the notice must be posted in a place where consumers seeking to make deposits are likely to see it before making their deposits. For example, the notice might be posted at the point where the line forms for teller service in the lobby. (Emphasis supplied)

What about the prohibition in Reg. CC that, "The disclosures shall be grouped together and shall not contain any information not related to the disclosures required by this subpart." Do you believe "Member FDIC" is not really "information" in this context?

You are going to imbed Member FDIC inside of the model Reg CC statement? That statement is really aimed at the written disclosures you are required to deliver. Having the Reg CC sign and FDIC sign on one piece of plastic I don't see as any big deal as long as the FDIC sign portion of it complies with the size and other requirements.

No, the Funds Availability Notice.

(b) Locations where employees accept consumer deposits. A bank shall post in a conspicuous place in each location where its employees receive deposits to consumer accounts a notice that sets forth the time periods applicable to the availability of funds deposited in a consumer account.

Still being within the same Subpart as the following:

§229.15 General disclosure requirements.

(a) Form of disclosures. A bank shall make the disclosures required by this subpart clearly and conspicuously in writing. Disclosures, other than those posted at locations where employees accept consumer deposits and ATMs and the notice on preprinted deposit slips, must be in a form that the customer may keep.

It would seem that 229.15 covers the disclosure required by 229.18(b)

It clearly indicates in 229.15(a) that the disclosure posted at locations where employees accept consumer deposits is within the scope of 229.15 by excluding it from needing to be made in a form the customer may keep. But, it doesn't exclude it from being written, nor does it seem to exclude it from not containing any information other than that within Subpart B of Reg. CC.

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| FDIC
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One piece of signage - tell me what is wrong with that? What is different about that then imbedding your written Reg CC disclosure into your overall account agreement with nothing but a separate heading?

I agree with Randy. The disclosures can still be "grouped together" even if they are on the same physical medium (plastic, paper, ect.).

Because the last sentence of 229.15(a) clearly says you can do that with other terms of the account.

(a) Form of disclosures. A bank shall make the disclosures required by this subpart clearly and conspicuously in writing. Disclosures, other than those posted at locations where employees accept consumer deposits and ATMs and the notice on preprinted deposit slips, must be in a form that the customer may keep. The disclosures shall be grouped together and shall not contain any information not related to the disclosures required by this subpart. If contained in a document that sets forth other account terms, the disclosures shall be highlighted within the document by, for example, use of a separate heading.

I don't see that to be the same thing as providing other Regulatory disclosures.

Just make sure the FDIC sign is the correct size of 7" x 3". Years ago the bank I worked for was cited because the size wasn't correct.