Are Google Adwords considered "advertisements" and therefore Member FDIC must be included in the words? The number of characters is very limited, so marketing does not want to include it. Of course, Google Adwords are not mentioned as advertising examples under Reg DD or Reg Z.

Mel, how would the Adwords advertisement not be a print ad? Aren't you advertising your bank's products and that ad appears beside certain search terms?

I'm not that familiar with Adwords but I don't see how they could be excluded.

As Dan mentions, it sounds like Google Adwords would be an advertisement as defined by the FDIC (Part 328). My emphasis added:

(a) Advertisement defined. The term "advertisement," as used in this part, shall mean a commercial message, in any medium, that is designed to attract public attention or patronage to a product or business.

In addition to FDIC requirements, be careful about Reg. Z and DD triggering terms and EHL logo requirements.

If the ad doesn't advertise any products or services -- Just the bank's name and address, for example -- It could be exempt from 328.3(c).

What about this John?

(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."

John -

I want to go with just the bank's name, but when I read the definition "to attract public attention or patronage to a product or business", it seems like the bank's name would be a "business".

In regards to the Google Adwords, either a product or the bank's name will always be part of the words. Marketing seems to think they can't live without those 8 characters.

Without the "offering a full range of banking services" in the example within the regulation, it would not meet the "promote non-specific banking products and services offered by the institution" piece of the trigger for the requirement. So if the ad only gave the name and location of the bank, my splitting of hairs say you would not need "Member FDIC." Of course if the "ad" doesn't mention products or services in any way, there's probably plenty of space (or character count) left for "Member FDIC."

What about these? The vendor, who has done these for other banks, stated Member FDIC and/or Equal Housing Lender logos only have to be a click away which they would be since the pages associated with the links would have them.

Local Banking at it's Best
www.abcbank.com
Make Mobile Deposits, Pay Bills Online, and Keep Your Money Local

or

Local Lender
www.abcbank.com
We've been financing homes for years. Contact us to get started

Ask the vendor to show you where that exemption (1 click away) is in Section 328 (Member FDIC) or the Fair Housing Act. It's definitely in Reg Z and Reg DD, but I'm not aware of any 1 click away rule for these two.

What David said ^^^ and "it's" is misspelled.

John has become my grammatical and spell correction. (floor vs. flood / it's vs. it is). Notice I answered that question at 9:45 PM on a Sunday night. That's my only excuse.

And I was in one of my nit-picking moods, David. Sorry. I thought the "flooded floor" bit was humorous. The "it's" thing was just being a PITA.

Resolution for 2018 -- "Always stay humble and kind." (Thanks, Tim McGraw)

Reviving this thread as I am not familiar with the Google Adwords. I've received one to review. It goes like this:

Home Mortgage
Bank Name
Competitive Rates
Then a sentence about why a home loan through us is a great idea.

Below that is a link to the bank's website
Equal Housing Lender (no logo?)
And a couple of links (like: Contact Us; Locations, etc.)

Is it okay to not have the EHL logo - but just have the words? Does the above look acceptable?