We have a new secured credit card product which is collateralized by funds held in a separate deposit account at the bank. I have reviewed 12 CFR 328.3 and am unclear if this product is considered a hybrid account. When this product is marketed should "Member FDIC" need to be included on the ad since funds deposited would be insured?

I don't know if you'll find a specific answer, but let me ask "why not include it?" Most banks put "Member FDIC" on loan ads. You're not promoting a hybrid product of FDIC and Non-FDIC insured types, so what's the risk?

Thank you!