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#99 - 11/28/00 02:28 PM Regulatory wallpaper - official FDIC sign at night depositories
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,704
Cape Cod
The currently-posted article (from a 1996 edition of Compliance Action) on mandatory signage reads, in part, "FDIC Deposit Insurance signs must be posted prominently at each teller station and wherever deposits are taken. The FDIC notice need not be displayed at ATMs but must be posted at each night depository" (emphasis added).
The FDIC has, in two opinion letters (#93-42 and #94-17) indicated that use of the official sign is not required at night depositories, since deposits are not considered accepted there.

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John Burnett
Cape Cod Bank and Trust

[This message has been edited by John Burnett (edited 11-28-2000).]

[This message has been edited by John Burnett (edited 11-28-2000).]

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General Discussion
#100 - 11/28/00 02:46 PM Re: Regulatory wallpaper - official FDIC sign at night depositories
David Dickinson Offline
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David Dickinson
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Central City, NE
John is correct. The FDIC announced years ago that the FDIC sign does NOT need to be posted at a Night Depository.
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#101 - 11/28/00 03:23 PM Re: Regulatory wallpaper - official FDIC sign at night depositories
Lucy Griffin Offline

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Lucy Griffin
Joined: Nov 2000
Posts: 1,544
John has it right! This illustrates the peril of using an older resource. But also, consider how to "post" the FDIC notice on web pages. That's where new wallpaper ideas will come into the virtual lobby.

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#102 - 11/28/00 03:50 PM Re: Regulatory wallpaper - official FDIC sign at night depositories
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,704
Cape Cod
Speaking of Web sites, I should have provided links to the two Advisory Opinions I found. http://www.fdic.gov/regulations/laws/rules/4000-1000.html#4777 and http://www.fdic.gov/regulations/laws/rules/4000-1100.html#4852
Then scroll down the page to the letters on topic.
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#103 - 11/29/00 05:17 AM Re: Regulatory wallpaper - official FDIC sign at night depositories
Andy_Z Offline
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Andy_Z
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On the Net
I would also recommend, as addendums to the required signage mentioned in the article,
1) the Equal Employment Opportunity poster required under 42 USC 2000e-10(a) since nobody else will be checking for it,

2) The early withdrawal penalty notice if you have a rate board under 217.6(e), and

3) An FCRA notice or error under 623(a)(1). If you notify customers where to direct their notice of error (of your report) that is where they must go. Otherwise, the customer could mention an error to a teller and you would be officially notified. The clock starts ticking at that time and you need to resolve the report and ensure erroneous information is not re-reported (read this as a liability). At least this was my reading of the amendments back in 96-97.

FYI, if you're interested, I hope to have my signage audit sheet posted on my personal web site later today or tomorrow. It is a Word file. It identifies 10 signage items (the 6 in the article, the 3 I mentioned and a Texas requirement.) Certainly you can edit it as you like for your bank and requirements.

It has a checklist and citations. It is designed so that others can read it, understand the requirements and assist in the branch signage audit process.
http://www.vvm.com/~zavoina/AndysPage.htm

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

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