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Make sure that your safe deposit box lease agreements contain verbiage that the contents are not insured by either FDIC or the bank; we put signs in all of the SD vaults stating that box contents are not insured by FDIC or the bank; and make sure that any advertising you do for safe deposit boxes doesn't say Member FDIC on it or use the FDIC logo. I don't have the links, but look up safe deposit boxes, 9/11, and the World Trade Center to read about the lawsuits brought by customers with SD Boxes located in the bank branches that were located in the WTC. Those customers were never allowed access and many of them thought that the contents were either covered by FDIC insurance or bank insurance - not a good assumption since we also have absolutely no idea of the contents of those boxes, but Joe Public makes his own assumptions.

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I have to double check, but I don't think it is non- compliant to have "Member FDIC" by your logo in an ad that mentions or advertises Safe Deposit Boxes. If so, you could never include SD Box infomation in a brochure.

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I don't have a cite reference, but you can't use Member FDIC in conjunction with an ad for a product that a customer may consider an asset when it isn't FDIC insured because it may be held to infer insurance. You can blend it into a brochure the same way you blend in investment or insurance products by adding a separate disclosure - for instance, if you have a folder with separate sheets for your various products, you could put a disclosure on that sheet. The way I understand the 9/11 safe deposit lawsuits, customers of those banks either considered it to be a "deposit" because that word is contained in the product (and yeah, that's moronic but stupidity isn't a protected class) or they assumed incorrectly that because it was in the bank that it was covered under bank catastrophe insurance. The only place I can think of to find a specific cite reference would be the FDIC regs but this may be more of a bank liability issue than anything. I don't want my bank to end up in court because someone thought we didn't do enough to let them know we weren't insuring the contents of their boxes (think McDonald's and the disclosure they put on coffee cups after getting sued because someone spilled hot coffee on their lap and said McDonald's should have TOLD them how hot the coffee was....).