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Combining Product Ads-Insurance, Mortgages etc.

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Our bank has numerous branches, a handful of insurance agencies, and also five office locations for non-deposit investment products. I am relatively new to the bank but not to compliance. In reviewing the bank's advertisements, there may periodically be an ad that talks about deposit products that are offered, "checking and savings accounts" and in addition may even mention "mortgages." In the same ad it may mention that we also offer insurance and investments. In the ad that refers to all these types of products, it will not state "Member FDIC" or "Equal Housing Lender" due to including the statement about insurance and investments. I am really having a hard time finding this acceptable even though one FDIC examiner has "OK'd" this type of combined ad in the past. Shouldn't the ad clearly segregate the bank's products and services from the non-deposit investments (with the required disclaimers) and insurance products? I have referred to Part 328 - Advertising of Membership of 12 U.S.C. 1818(a) etc., I just need to know if I am understanding the requirements correctly.

All requirements apply; there is no exemption for multi-product ads. NDIP products should be clearly separated from insured deposit products. The fact that one FDIC examiner has passed this sort of ad in the past should never be a consideration when you're reviewing ads for compliance. If there are problems, they will get caught by an examiner or auditor eventually.

First published on 8/6/12

First published on 08/06/2012

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