FDIC recently released the FDIC advertisement of membership proposal (see http://bankersonline.com/topstory/fedreg/71FR06-6261.pdf) - sorry if the link doesn't work since I haven't figured out how to add a hyperlink. I would urge everyone to comment (you can see my comments at http://www.fdic.gov/regulations/laws/federal/2006/06commembership.html). The FDIC previously had 20 exemptions for using the "Member FDIC" on advertising. They have proposed eliminating 15 exemptions, some that you may not beware of. The proposal adds a definition for advertisement that "means a commercial message, in any medium, that is designed to attract public attention or patronage to a product or business." The FDIC advertising statement also would need to be included in ALL advertising that either promotes deposit products and services OR generally promotes banking services offered by the institution. That is ambiguous to me and could mean simply having your bank name on an envelope that the customer uses to put their withdrawal in. Some of the exemptions that have been eliminated from the proposal include statements of condition, bank supplies (such as stationery, envelopes, deposit slips, signature cards), listings in directories, advertising for loans, and others. My biggest concern is "bank supplies" would need to have MEMBER FDIC shown if it contains a commercial message to attract attention to our bank and generally promotes banking services. That could be almost any type of bank supply that is used. As an example, we have small post-it notes that states "Thank you for recommending C&C Bank." IMO, this would now need MEMBER FDIC shown on it since it promotes our bank. The proposal also has the revised FDIC sign. The drafted language on the FDIC official sign shows "Each depositor insured to at least $100,000." Well, what happens if the rate of inflation changes in five years and the $100,000 changes. Are we going to have to change our FDIC signs every five years? I would urge you to comment on this and if you want some of the same exemptions to remain such as "bank supplies." I know I'm putting my two cents worth in!

Thanks for the heads up - I had not read this one yet and now know that I need to comment.

I might be misunderstanding this, but my reading of the proposal is that they have eliminated these exemptions because they aren't included in the definition of "advertisements that either promote deposit products and services or generally promote banking services offered by the institution" so they would not need the Member FDIC statement anyway. I would say your post-it notes would be included in the exemption that still remains "(4) Advertisements which are of the type or character that make it impractical to include the official advertising statement, including, but not limited to, promotional items such as calendars, matchbooks, pens, pencils, and key chains;" I would say the post-it notes would not require it if calendars don't. Maybe I'm reading this wrong???

cnakashige-

links don't work if you end with a close parenthesis or a period. I try to put the link on a separate line after I explain the link and say something like available at:

http://www.fdic.gov/regulations/laws/federal/2006/06commembership.html

Al