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Cell Phone Banking - Display FDIC & EH Logo

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Question: 
We are an OCC regulated national bank and a beta test bank for mobile banking. Our customers can use their cell phones or PDAs to view account balances, transactions, transfer funds intrabank, and pay bills. Account numbers are not displayed only account nicknames. There is no advertising of products or rates. The only picture displayed is the bank's logo. Do we need to display the FDIC or Equal Housing logo on any or all the pages displayed on the cell phone?
Answer: 

No for both. As long as you are not advertising a new deposit product the FDIC logo or "Member FDIC" or any other acceptable variation is not required. There is no requirement that your bank statement tell a customer that the current account is FDIC insured. You already did that. You must do this if you advertise a new product that is insured.

The Equal Housing Lender logo is required by most regulatory agencies when you advertise a housing related loan product. The OCC however, referred in their requirement to a HUD publication that required this. HUD edited that document and there is no longer a reference to the logo. The OCC never amended their side, so there is no requirement for a national bank to use the EHL logo. Displaying the EHL logo is still a best practice and I'd encourage national banks to use it in advertisements.

First published on BankersOnline.com 5/26/08

First published on 05/26/2008

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