FDIC Digital Sign Requirement
Just before Christmas on December 23, 2023, to be precise, the Federal Deposit Insurance Corporation (“FDIC”) Board of Directors gave a Christmas gift that was the equivalent of coal in their stocking. Since the 1930s, when the FDIC was founded as part of the New Deal, the black and gold official sign (shown below) displayed at bank branch teller windows has given bank customers confidence that their deposited funds are safe.
Upon opening their stocking, bankers learned that the FDIC Board had adopted a final rule to amend part 328 of its regulations to modernize the rules governing the use of the official FDIC signs and advertising statements, and to clarify the FDIC’s regulations regarding false advertising, misrepresentations of deposit insurance coverage, and misuse of the FDIC’s name or logo.
Driven by the fact that depositors and consumers today have a variety of options for where they can deposit their money and how they can access banking products and services, the new rule is seeking to extend the certainty and confidence associated with the FDIC official sign to digital channels, such as banking websites and mobile apps, through which depositors are increasingly accessing their deposit funds and banking needs.
New Rule Established
However, rather than the same sign to be put online, the December 2023 rule established a new black and navy blue official digital sign shown below:
Beginning on New Year’s Day 2025, banks will be required to display the FDIC official digital sign near the name of the bank on all bank websites and mobile applications. Banks will also be required to display the FDIC official digital sign on certain automated teller machines.
Under the final rule, Insured Depository Institutions (“IDIs”) are required to display the FDIC official digital sign “clearly and conspicuously” in a continuous manner; the official digital sign continuously displayed at the top of the relevant page or screen and in close proximity to the IDI’s name would meet the clear and conspicuous requirement standard.
What Perficient has been seeing in the industry is that since an IDI’s mobile apps and websites must be altered for the new FDIC signage, bank executives are taking the opportunity to kill two birds with one stone and revamp their website and mobile apps to improve the user experience and enhance security while meeting the new FDIC signage requirements.
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