Actual case on point for this. "Back in the day" not all banks had websites or internet banking. To market internet banking they showed screenshots of the program using dummy account info. These screenshots did not show "Member FDIC" because the program doesn't have that on the pages - these were (simulated) existing customers with existing account information. The problem was, when you use that screenshot to sell the product with new accounts, it is an ad and the disclosure was required.
As Richard noted, no NDIPs, no downside. And to the OP, it's not a violation to not have it but things sometime get repurposed and that's when each needs to be reviewed, as in my example.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell