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#457634 - 11/16/05 04:39 PM Materials mentioning deposit, loan and NDIPs

We have marketing materials describing the range of Private Banking Services that we provide, including deposit, loan and NDIPs - all on the same page. Should the literature include the Member FDIC, Equal Housing Lender AND the NDIP (i.e., not guaranteed by any bank, etc) disclosures all on the same page?

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#457635 - 11/17/05 07:51 PM Re: Materials mentioning deposit, loan and NDIPs
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,785
Cape Cod
Yes. And be very sure that you've done something to very clearly distinguish the deposits from the NDIPs. The FDIC is particularly ticklish on this issue, and merely annotating that specific products are NDIPs isn't adequate. You should keep the two in separate sections of the materials, with a clear boundary between them.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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#457636 - 11/17/05 07:52 PM Re: Materials mentioning deposit, loan and NDIPs
Andy_Z Offline
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Joined: Oct 2000
Posts: 27,542
On the Net
The NDIP needs to be segregated so that it does not appear that it is also FDIC insured. That disclosure is required because of the deposit ad. In most case it is easier to separate the ads. If you can't, make darn sure the reader knows these are separate.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#653841 - 12/18/06 09:05 PM Re: Materials mentioning deposit, loan and NDIPs Andy_Z
M Cockrell Offline
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M Cockrell
Joined: Jan 2003
Posts: 1,038
Dallas, TX
Are NDIP requirements only applicable to retail customers (AKA "consumers")?

If a brochure insert is specifically geared toward (non-retail) commercial clients ONLY, but has both insured & non-insured products/services listed, do the products/services need to be "segregated" and the insert include the "minimum disclosure" information?
Last edited by M Cockrell; 12/18/06 09:36 PM.
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