Does anyone have a chart that shows what the mandatory sign postings are for bank lobbies? We are a National Bank, regulated by OCC.

If a chart isn't available, does anyone know of an "easy" reference guide that I could look at?

Thanks for any help offered!

Try these: http://www.bankersonline.com/infovault/sinfovault.html#signage
http://www.vvm.com/~zavoina/signage.htm
http://www.bankinfo.com/training/notices.html

Here's a portion of the Advertising section of our Deposit Operations manual:
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LOBBY DISCLOSURES



FDIC Signs:
A bank shall display an FDIC sign wherever deposits are accepted; however, there are several exceptions. FDIC signs should be placed at each teller station, and at the drive up. Signs are not needed on ATM’s. If loan officers receive deposits in their offices, then technically, an FDIC sign should be located there as well.

Funds Availability Disclosures:
The general policy of the institution should be displayed conspicuously in each location where deposits are received. A notice need not be posted at each teller window, at a drive up facility nor at the night depository. Funds availability notices are required at ATMs that accept deposits.

CRA Notice (lobby poster):
The CRA notice must be displayed in each office of the institution other than off-premises electronic deposit facilities. The CRA notice must state the prescribed language as set forth in the regulation [Regulation BB (Federal Reserve), Part 345 (FDIC) or 12 CFR 25 (OCC)]. The language of the CRA notice varies depending on whether branches are located in the same or separate delineated community as the main institution.

Financial Disclosure Statement:
This regulation [Part 350 (FDIC) or 12 CFR 18 (OCC)] requires banks to make available to the public parts (or all if you desire) of the institution’s CALL reports for the last two year-ends. A bank shall display, in the lobby of its main office and at each branch, a notice that the annual disclosure statement may be obtained from the bank. The disclosure statements must contain the following disclaimer: “This statement has not been reviewed, or confirmed for accuracy or relevance, by (the institution’s regulatory agency).” Additionally, an officer of the bank shall sign the statement and shall attest to the correctness of the information contained in the statement.
Federal Reserve and OTS regulated institutions no longer need to comply with these requirements.

Fair Housing Lending Poster:
This regulation [Section 6-1500(2)(a) (Federal Reserve), Part 338.4 (FDIC), or 24 CFR 109 (OCC)] requires institution’s to display the poster in a central location within the bank where deposits are received or where home loans are made in a manner clearly visible to the public entering the area. The poster is not required at ATMs or drive-up windows. The poster should provide the name and address of the institution’s primary regulatory agency (FDIC, Federal Reserve or OCC). The poster must be exactly eleven inches by fourteen inches.

Home Mortgage Disclosure Act (HMDA):
Regulation C does not apply to banks that: (1) have neither a home office nor a branch office in a Metropolitan Statistical Area (MSA); or (2) have total assets of $32 million or less. Banks must collect data regarding applications, on a Loan Application Register (LAR), for home purchase and home improvement loans (including refinancings of both) for each year. Home purchase loan is defined as any loan secured by and made for the purpose of purchasing a dwelling (any residential structure). A home improvement loan means any loan for the purpose of repairing, rehabilitating, or remodeling a dwelling.

Availability of the LAR. A bank shall make the LAR available at its’ home office. If the bank has a branch office in other MSA’s, the LAR shall also be available in at least one branch office in each of those MSA’s. The LAR at a branch office need only contain date relating to property in the MSA where that MSA is located. Institution’s shall make the LAR available for five years (since 1990).

Disclosure to the public. A bank must post a general notice about the availability of its’ LAR in the lobbies of its' home office and any branch office located in a MSA. Upon request, the bank shall provide the location of the institution’s offices where the LAR is available. The bank may include the location of the LAR in its notice.

Rate Boards and All other advertisements inside the bank:
If you state “See an employee of this institution for further information,” you only need to state the following:
· The APY (using that term or Annual Percentage Yield); and
· Member FDIC.
The “interest rate” (using this term) may be disclosed at your option.

Disclosure of ATM surcharges:
The Gramm-Leach-Bliley Act requires that ATM operators that impose an ATM surcharge to:
1. Post a notice on the machine that a surcharge may be imposed, and
2. Inform the consumer, either through on-screen message or paper receipt, of the amount of the surcharge before the consumer is committed to completing the transaction (Opt-out).
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I thought you also needed the FDIC brochure "Your Insured Deposit" available in your lobby.

Do we also need to post a disclosure that safe deposit box contents are not FDIC insured? Our disclosure in our rental contract states this, but do we need to post the disclosure in the safe deposit area and/or lobby? It seems this has come up since the World Trade Center attack because some box holders in banks in the Centers were under the impression the contents of their deposit boxes were FDIC insured. I understand there are some law suits being filed. I am not aware of any new requirements and this may only be a precaution. Does anyone know?

It isn't a law as far as I know, but having a sign posted in the safe deposit area is highly recommended. We have it in our brochure and we have very conspicuous signs posted on the wall as a customer enters the safe deposit vault.

A speaker at a conference I recently attended stated that if a consumer were allowed to submit an application via the website, the site could be deemed a "lobby" or a "branch" for purposes of various regulations. And, as such, consideration should be given to posting required "lobby" notices on the site. Should some or all of the notices reflected in David's response be posted? Is there any other guidance out there that addresses this issue? How is everyone else handling this?

Isn't the requirement for the Financial Disclosure Signage by Federal Reserve Banks discontinued?

In most cases there isn't a formal requirement for lobby signage in your virtual lobby. That said, it takes minimal time and no on-going maintenance to support them. Why not add them in as CYA?

BankersOnline is pleased to offer a product in our Banker Store that helps decipher the various requirements relating to regulatory wallpaper. It was developed by the Massachusetts Banker's Association -- it provides a complete database of all the signage requirements. You may want to check out the Guide to Federal Regulatory Policies and Signage Requirements in the Compliance Aids section of our Bankers Store at:

Guide to Federal Regulatory Policies and Signage Requirements

I have a question regarding the fair housing poster. In an office where loans are underwritten but the office is not open to the general public, is the fair housing poster still required to be displayed?

No. If members of the public can't visit the office to make an application, there's no need for the poster. Consider the purpose of the poster is to notify members of the public of the law and provide information on whom to contact for any problems.

Great, thanks!

Are there any restrictions to having the signage board behind the teller station as long as it is readable by the consumers?

Some of our branches are supermarket branches, and this is all we can support. If the branch contains a lobby, must it be located in the actual lobby?

Thanks in advance.

I believe what matters is that they be clearly readable to anyone concerned. A 8.5x11 HMDA notice would be tough to read at 15 feet, but you know your branch layouts better than I. Depending on the distance and height it might work or it might me deemed lip service.

We are opening a new branch and Marketing would like to display our lobby signs on a digital board. I haven't seen the blueprints myself but there may not be a space to put posters where they can be easily viewed. My initial thought is no given the size requirement for the Fair Housing poster. But if the screen is bigger than those requirements, then maybe we are ok? My second thought is if the disclosures are running by too fast, how will anyone be able to read them and capture the contact information? Sounds like there will be two digital screens - I haven't confirmed but maybe one for disclosures and one for ads? I feel like this is a no but I want to be open minded and search for a yes answer.

Is this idea even feasible? The rule keeps referring to "poster" which makes me think it needs to be paper. Then again, the rules are so outdated and doesn't speak to electronic delivery. Any thoughts on this?

As long as they are displayed - I would have no problem with it. If you mean that one screen will cycle through all the various disclosures required to be posted - I don't think that is going to cut it because at some point in the cycle, they are no longer displayed.

My understanding is the screen would cycle through, one disclosure at at time. So technically the wouldn't all be displayed at once. If that's the requirement, then the digital display option won't work. I know Marketing will push back hard on this one so anything I can point to in support of the "must be displayed all at once" would be helpful.

§ 110.15 Location of posters.

All fair housing posters shall be prominently displayed so as to be readily apparent to all persons seeking housing accommodations or seeking to engage in residential real estate-related transactions or brokerage services as contemplated by sections 804 through 806 of the Act.


I would be hard to say that it is prominently displayed if it just shows up in a rotation of other information.

Thanks Randy. I completely agree for this disclosure. The others don't speak so clearly.

Since you won't be able to find where it says you can't do this - ask your marketing group to find where it says you can.

Reg CC 229.18(b) (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.

Same comment as Randy. How is a disclosure "conspicuous" if I have to wait several minutes for it to cycle through.

I will do what I always do - give them the requirements, my recommendations, the risk and let them decide. Most often the compliance recommendation is followed but not always, I can see this one being the latter given the risk. I know, I know. I don't like it either but the likelihood of there being a problem is low IMO - lose the battle, win the war? Document, document, document and if / when it comes back as an issue, I can provide my recommendation that was not followed.