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"
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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