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#2206983 - 02/25/19 03:49 PM Advertising the Bank's Name
Anonymous
Unregistered

If we order caps to give away to customers, management wants to just use the bank's logo. Do we need to spell out the Bank's name and add Member FDIC or can we just use the Logo and member FDIC?

Thanks!

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#2207018 - 02/25/19 06:46 PM Re: Advertising the Bank's Name Anonymous
Anonymous
Unregistered

Original anon here, Can anyone give me any guidance on this?

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#2207020 - 02/25/19 06:56 PM Re: Advertising the Bank's Name Anonymous
P*Q Offline

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Why wouldn't you put the Bank's name too? If the caps are being worn out in public, folks may not know the name of the Bank with just a logo so add the Bank name if you're looking for publicity (although I'm not sure why the funds would be expended on caps customers may never wear). We have Bank hats, etc for employees and there are no FDIC logos, etc.

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#2207025 - 02/25/19 07:14 PM Re: Advertising the Bank's Name P*Q
Anonymous
Unregistered

Original anon here: I totally agree. Thanks so much for your comments!

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#2207154 - 02/26/19 07:30 PM Re: Advertising the Bank's Name Anonymous
burke116 Offline
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Joined: Jun 2014
Posts: 566
Petersburg, VA
Quote:
(although I'm not sure why the funds would be expended on caps customers may never wear).


We had hats made once a few years back and they were a big hit with our customers. We still have people coming in asking for one.

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#2207176 - 02/26/19 08:35 PM Re: Advertising the Bank's Name burke116
RockChucker, CAMS Offline
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Joined: Jul 2013
Posts: 1,700
The Country
Originally Posted By burke116
Quote:
(although I'm not sure why the funds would be expended on caps customers may never wear).


We had hats made once a few years back and they were a big hit with our customers. We still have people coming in asking for one.


I agree burke, we buy really nice quality fitted hats and give them away, they are always a big hit and people wear them around town because they look good and fit good.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

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#2207184 - 02/26/19 08:49 PM Re: Advertising the Bank's Name Anonymous
P*Q Offline

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P*Q
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All the more reason then to put the name along with the logo! Advertising! smile

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#2207207 - 02/26/19 10:18 PM Re: Advertising the Bank's Name Anonymous
HappyGilmore Offline
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Joined: Jun 2004
Posts: 19,854
Pulling people out of the ditc...
i don't have a proper hat head, so if you ever see some goofy looking guy with a hat on his head and the hat sits like Charlie Brown's does in the peanuts cartoon, come tell me hello...
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Providing alternative truths since the invention of time

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#2207208 - 02/26/19 10:18 PM Re: Advertising the Bank's Name Anonymous
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,658
Originally Posted By Anonymous
If we order caps to give away to customers, management wants to just use the bank's logo. Do we need to spell out the Bank's name and add Member FDIC or can we just use the Logo and member FDIC?

If it is just your bank logo, you shouldn't need member FDIC. This is due to two things. First, you aren't advertising specific deposit products/services or non-specific products/services.

(c) Use of official advertising statement in advertisements--(1) General requirement. Except as provided in § 328.3(d), each insured depository institution shall include the official advertising statement prescribed in § 328.3(b) in all advertisements that either promote deposit products and services or promote non-specific banking products and services offered by the institution. For purposes of this § 328.3, an advertisement promotes non-specific banking products and services if it includes the name of the insured depository institution but does not list or describe particular products or services offered by the institution. An example of such an advertisement would be, "Anytown Bank, offering a full range of banking services."

As you can see, as long as you aren't advertising products/services, you could even list your name without including "Member FDIC."

Secondly, if the "advertisement" doesn't mention your name, it is exempted from the "member FDIC" requirement:

(d) Types of advertisements which do not require the official advertising statement. The following types of advertisements do not require use of the official advertising statement:
(5) Advertisements not setting forth the name of the insured depository institution;
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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