"Signs without any specifics"

We have some new signs throughout our lobby that do not promote directly any products. They say things like, "What are you dreaming of...." and then there are pictures of houses, vacation spots, etc. Our bank's name isn't even on the sign but they are located inside our buildings. My question is do we have to have the equal housing and fdic stuff on these since we don't actually mention any product? Of course we're trying to get people to ask about a loan but we aren't saying that....

Sounds like creative imagery advertising and yes, I would require the necessary logos depending on what "vision" I was taking from the signs.

As far as the FDIC logo, it would not hurt to put it on there, but ads without the bank name are specifically exempted so your signs are compliant as is.

Additionally the FDIC logo is not required on ads related to loans so you are also compiant in that respect.

§ 328.3 Mandatory requirements with regard to the official advertising statement and manner of use by banks.

(a) Insured banks to include official advertising statement in all advertisements except as provided in paragraph (c) of this section. Each insured bank shall include the official advertising statement, prescribed in paragraph (b) of this section, in all of its advertisements except as provided in paragraph (c) of this section.

(c) Types of advertisements which do not require the official advertising statement. The following is an enumeration of the types of advertisements which need not include the official advertising statement:

(5) Advertisements not setting forth the name of the insured bank;

(12) Advertisements relating to the making of loans by the bank or loan services;