Our online banking vendor offers a marketing service where they create "engagements" that run for certain periods of time. These engagements produce certain advertisements that pop up when a customer signs into their online banking. For example: if a customer hasn't signed up for online bill pay or has not used their online bill pay for a certain period of time - then advertisements would pop up at sign in to online banking and certain "banner ads" would appear within the online banking platform. My question is, would these ads need to follow all compliance rules since they are showing up only within the banks online banking platform? For instance, do they need to have Member FDIC located within the ad? When the ad pops up at sign in, nowhere on the screen does Member FDIC appear. However, once the customer moves on into the platform, then Member FDIC appears at the bottom of the page. So, I wasn't sure if we would even need for that to appear in the "banner ad". I wasn't aware of these ads until recently and when I asked our marketing dept about them I was told that we could change or remove them, but it is up to us to review them when the new engagements are released. Which we haven't been doing.

Should we be following the same advertisement procedures for these advertisements as we do for our normal advertisements? Does anyone else deal with anything like this?

Thanks!

If you give me a banner ad for the savings product I have, no Member FDIC would be needed. But if you gave me an add for a DDA when all I have now is a savings, then yes the FDIC is required.

The fact that is within your internet banking program doesn't matter here as it's still an advertisement.

The CAN-SPAM rules are impacted when it is a closed system, but that isn't really your question.

Thank you Andy. I appreciate your help!