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#2272226 - 06/28/22 11:21 PM FDIC’s Final Rule on Misuse of FDIC logo
c@c Offline
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Posts: 113
Georgia
In the FDIC's recent new rules regarding advertising of membership that go into effect in August, they define an “Uninsured Financial Product” as any non-deposit product, hybrid-product, security, obligation, certificate, share, or financial product other than an insured deposit

We routinely include the FDIC logo on all communications unless the communication specifically addresses non-deposit investment products. Outside counsel recently opined that we may now be prohibited from including the FDIC logo on communications where a loan product is being advertised. Is anyone else hearing this from outside counsel. regulatory agencies or concluded this internally? We do a lot of mixed advertisements for both deposits and loans, so it becomes more problematic in those instances if this interpretation holds water.

Just wondering if anyone else is hearing this?

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#2272233 - 06/29/22 12:40 PM Re: FDIC’s Final Rule on Misuse of FDIC logo c@c
rlcarey Online
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rlcarey
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Galveston, TX
I think they are making a mountain out of a molehill unless you are slapping the logo on a NDIP. The whole target of that regulation is actually non-bank entities. A regulator is not going to bat an eye if you put the FDIC logo on an ad for a loan product.
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#2272284 - 06/29/22 07:02 PM Re: FDIC’s Final Rule on Misuse of FDIC logo rlcarey
c@c Offline
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Georgia
That is exactly my thought as well, Randy. Thanks for your response.

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#2272294 - 06/29/22 10:07 PM Re: FDIC’s Final Rule on Misuse of FDIC logo c@c
Andy_Z Offline
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The thrust was directed at bad actors advertising FDIC when they were not and the new rule going into effect July 5 is really aimed at them. Banks could be included, but the majority of what the FDIC is trying to fix is not in a bank. The revised 12 CFR 328 will establish procedures the FDIC to follow for identifying, investigating, and taking formal and informal action to address potential violations of Section 18(a)(4).
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#2272426 - 07/05/22 08:07 PM Re: FDIC’s Final Rule on Misuse of FDIC logo c@c
John Burnett Offline
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John Burnett
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Cape Cod
If a bank has an employee who is misrepresenting FDIC coverage limits due to lack of training, the bank could attract the FDIC's attention. but that's always been the case. The changes to the rule are really about (as suggested above) non-banks and other entities misrepresenting themselves as having the FDIC deposit coverage. And it provides the structure the FDIC will follow to pursue such bad actors.

If a bank has problems giving out bad info on coverage or breaking the rules on advertising FDIC membership, there is already a good structure for the FDIC to follow up -- exam citations, C&D orders, CMPs, etc.
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