A series of proposed changes to the FDIC’s recently revised signage requirements is a positive step forward, but further changes are needed to ensure clarity and avoid confusion for depositors and other bank customers, the American Bankers Association and Bank Policy Institute said in a joint letter.
In 2023, the FDIC issued a final rule that revised requirements for the use of the agency’s name and logo by banks, including on digital channels and ATMs. The requirements were scheduled to take effect in March 2026, but in August of this year, the FDIC issued proposed rulemaking to make further amendments to the digital signage requirements. It also proposed pushing back the compliance date for certain sections to Jan. 1, 2026.
In their letter, ABA and BPI said that because each bank’s digital channels are unique, “there is an almost infinite number of website and mobile application designs that banks may adopt.” They suggested the FDIC provide banks with additional flexibility to place the FDIC official digital sign and other disclosures on digital channels “in a way that provides clarity in the context of the specific bank’s product offerings and digital display and functionality.”
ABA’s and BPI’s primary recommendations were that the FDIC eliminate the following requirements:
- The FDIC official digital sign appears on login and home pages;
- The nondeposit signage appears as a one-time notification for bank customers related to third-party non-deposit products (or, at a minimum, that the FDIC excludes affiliates from this requirement);
- Static nondeposit signage be displayed on digital deposit-taking channels.
The associations also made other recommendations, such as the FDIC eliminate existing FAQs on digital and ATM signage placement to provide banks more flexibility in compliance, and that banks be given at least 18 months to comply with a final rule.
