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#2239802 - 07/17/20 10:02 PM Member FDIC
banker-12 Offline
Diamond Poster
Joined: May 2007
Posts: 1,240
Employees are making or obtaining their own face masks and including the bank name and logo. The Member FDIC statement is not required because the bank is not the one providing the face masks as promotional items, correct? The employees are wearing them at the bank.

Thanks,

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Marketing
#2239805 - 07/18/20 12:15 PM Re: Member FDIC banker-12
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
I truly think that you have more important things to take up your time worrying about - regardless of what the correct answer might be.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2239807 - 07/18/20 03:45 PM Re: Member FDIC banker-12
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,658
I agree with Randy that this is probably not worth the battle at the moment. A best practice for your marketing team would be to incorporate "Member FDIC" into the actual logo so anytime the logo is used the disclaimer is already there. I've seen some designs that do a great job including "Member FDIC" without really taking away from the branding - i.e. the Member FDIC just becomes part of the brand. But again, that is probably a battle for another day.

As far as the technical answer, here is what the rules say:

"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"

In addition, the exemptions (where member FDIC is not required) include this:
"Advertisements not setting forth the name of the insured depository institution"
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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