FDIC Federal Register Citations
First United Bank & Trust
August 29, 2006
Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW,
Washington, DC 20429
SUBJECT: Advertisement of Membership
Dear Mr. Feldman:
Thank you for the opportunity to comment on the Proposed Rule issued on
July 17, 2006 on Advertisement of Membership. Please consider the
following comments;
Advertising for non-deposit products (NDPs) or hybrid products that
offer both NDP and deposit-related products or services - This is
generally a matter of uncertainty for compliance officers and needs
clarification. Our Marketing Department frequently includes all the
services that are offered by our trust department, investments, and
insurance agency in one advertisement with traditional bank products... It
is sometimes challenging to comply with the FDIC regulation and the
Interagency Policy Statement on Retail Sales of Nondeposit Investment
Products for one advertisement containing both of these components. I
recommend that the official advertising statement be plainly clarified for
these two regulations.
Section 18(a)(1)(A) of the FDI Act states that each insured
depository institution shall display, at each place of business maintained
by that institution, a sign or signs relating to the insurance of the
deposits. Section 328 could be modified to require the official sign to be
displayed at each bank entrance accessible to customers as opposed to each
station or window where insured deposits are usually and normally
received.
It is understood that institutions will be allowed to order as many
signs as needed to comply with the final regulation at no cost to the
financial institution. This, however, is a cost to taxpayers in general,
for a change that could be considered without substantive difference.
Perhaps a grandfathering approach would be in order to allow current
signage to remain in compliance until replaced, etc.
Thank you for your consideration of these comments under the Notice of
Proposed Rulemaking for Advertisement of Membership.
Respectfully,
Jeanette L. Wampler
VP & Compliance Officer
First United Bank & Trust
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