As you already know, Happy, the main guidance for this is the FDIC membership rules and NDIP rules which both say to clearly segregate, but don't give further direction. As Skittles pointed out, it would seem to me that the "Always Insurance/Always Investment/Always Bank" doesn't clearly explain to consumers which products are FDIC insured and in my opinion, having the Not Not May right next to the Member FDIC is confusing - at best. Without seeing the full ad (which isn't possible on these forums), it is hard to give further direction or opinions. If your marketing team insists on this approach, you may want to contact your primary regulator to get their blessing in advance of the ad (though their "blessing" doesn't guarantee that others won't later disagree).
Hope that helps and best of luck working with your Marketing team.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com