Marketing "Not FDIC Insured" Insurance Products

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Question:

We are an insurance agency offering discounts to customers of a bank. The discounts apply to property and casualty insurance. Do we need to include "not FDIC insured" on our marketing materials? If so, what is the proper verbiage? Our marketing materials include the bank's name and logo.

Answer:

Advertisements and promotional material of insurance products or annuities requires the following insurance disclosures unless they are of a general nature [Refer Section 343.40(d)].

The following may be used for visual media, ATM screens, billboards, signs, posters, written advertisements and promotional material:

Not a deposit
Not FDIC insured
Not insured by any federal government agency (if applicable)
Not guaranteed by the bank
May go down in value (if applicable)

You also need to make sure that your advertisements do not state "member FDIC". When advertising both insured deposit products and non-deposit products (such as an insurance product), you must clearly segregate the official statement ("member FDIC") from the advertisement that relates to the non-deposit products. Refer to Section 328.3(e) for more information.

First published on BankersOnline.com 6/11/07