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#2216242 - 06/21/19 02:33 PM Bank Sign
Banker57 Offline
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Joined: Jul 2010
Posts: 439
Minnesota
Regarding an outside sign, attached to the building with the bank name only - is Member FDIC required? It is not an advertisment simply a 'we are here' sign. I am thinking since it is not a "advertisement" including the FDIC info is not needed. However the more threads I read,I find conflicting information. Reading the reg I only see a reference to advertising. Anyone help clear this up?
thank you,

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#2216250 - 06/21/19 04:28 PM Re: Bank Sign Banker57
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,436
Somewhere
You mean the sign that labels your bank is there? We don't use the symbol, have yet to see a Bank that does externally when referring to the sign that is your name that tells people that's where you are located.

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#2216299 - 06/22/19 04:41 AM Re: Bank Sign Banker57
Inspector Offline
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Posts: 254
You stated the sign is attached to the building, the statement is not required.

(d)Types of advertisements which do not require the official advertising statement. The following types of advertisements do not require use of the official advertising statement:

(3) Signs or plates in the insured depository institution offices or attached to the building or buildings in which such offices are located;
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#2256040 - 06/28/21 03:37 PM Re: Bank Sign Inspector
travelgirl1 Offline
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Joined: Sep 2015
Posts: 81
What if the sign is not attached to the building but rather sits along the road? I'm inclined to still say 'no' to including Member FDIC.

Further, some of the bank's offices also have an affiliate insurance agency within the bank (separated by a separate entrance within the lobby or a distinct separate by walls, cabinets, etc.). Having a sign along the road which says "Member FDIC" would muddy the waters for those offices with an insurance agency....another reason to not include it.

IMO, this is likely very low risk too.
Last edited by travelgirl1; 06/28/21 03:46 PM.
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#2256052 - 06/28/21 05:34 PM Re: Bank Sign Banker57
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
(d) Types of advertisements which do not require the official advertising statement. The following types of advertisements do not require use of the official advertising statement:

(3) Signs or plates in the insured depository institution offices or attached to the building or buildings in which such offices are located;

A sign by the road is not exempt from the Member FDIC requirement.

I am not sure how an insurance affiliate entered into the discussion. Advertising a bank is not advertising an insurance affiliate unless it would be a very specific sign identifying the insurance affiliate.
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#2256054 - 06/28/21 05:53 PM Re: Bank Sign rlcarey
travelgirl1 Offline
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Joined: Sep 2015
Posts: 81
Thanks Randy.

The insurance part came in because the bank building has an insurance company affiliate within it. If we have "Member FDIC" on the sign along the road (which it sounds like we need it), I didn't want to give the perception that all activities (such as deposit accounts) are FDIC insured, which they are not due to the insurance business. I may be thinking too hard on this.

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#2256057 - 06/28/21 06:26 PM Re: Bank Sign Banker57
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
If you have a sign by the road that says ABC Bank - I assume your insurance company is not called ABC Bank.
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