Answer by John Burnett:You're not required to include the Member FDIC statement or any other indication of FDIC insurance on this ad, and, frankly, I recommend against it. It's bad enough that folks sometimes think that "safe deposit" suggests that whatever they stick in one of those boxes is a deposit and therefore insured.
Answer by Jim Bedsole: The citation to rely on for John's statement is 12 CFR 328.3(c)(1) which states: Except as provided in Section 328.3(d), each insured depository institution shall include the official advertising statement prescribed in Section 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.
Your advertisement does not promote deposit products and services, nor does it promote non-specific banking products and services offered by your bank. Therefore "Member FDIC" is not required.
First published on BankersOnline.com 2/18/13