Below are answers to a collection of questions about the FDIC’s regulation, Official Signs and Advertising Requirements, False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC’s Name or Logo (“regulation” or “part 328”), 12 CFR part 328. This collection of questions and answers will be periodically updated on the FDIC’s website.
Please Note: On January 29, 2026, the FDIC amended requirements relating to the display of the FDIC Official Digital Sign and other signage on insured depository institution (IDI) websites, mobile applications, and automated teller machines (ATMs) in sections 328.4 and 328.5 of the regulation. The compliance date for these amended provisions is April 1, 2027. For more information, please see the Financial Institution Letter (FIL-3-2026).
The answers below are updated as of May 13, 2026 unless otherwise indicated.
I. Physical Premises
A. FDIC Official Sign
1. With respect to the display of the physical FDIC official sign, does the regulation require the FDIC official sign to be posted at a new accounts desk?
Answer: If a banker at a new accounts desk “usually and normally” receives and processes deposits (e.g., processes a check deposit at the new accounts desk), then the official sign must be posted at the new accounts desk. In a scenario where the banker at the new accounts desk always walks the initial deposit over to the teller line, then the teller is “receiving” the deposit and the official sign posted at the teller window is sufficient; therefore, in that situation, an official sign would not be required at the new accounts desk.
(Updated May 13, 2026)
2. Are IDIs required to provide any initial disclosures about FDIC insurance coverage, either orally or in writing, before opening an account?
Answer: No. Part 328 does not require IDIs to provide “initial disclosures” about FDIC coverage before account opening.
(Updated July 15, 2024)
3. Is the FDIC official sign required at night drop facilities?
Answer: No. The official sign is required wherever deposits are usually and normally received. FDIC staff does not view that deposits are usually and normally received by the IDI when placed in a night depository.
(Updated July 15, 2024)
4. What are the display requirements for the physical FDIC official sign?
Answer: The regulation requires use of the standard, in-branch official FDIC sign, which is 7x3 inches in size with black lettering and gold background. Upon request, the FDIC will continue to provide the official sign at no cost to IDIs. As has been the case traditionally, IDIs may, at their expense, procure from commercial suppliers signs that vary from the official sign in size, color, or material. An IDI may display signs that vary from the official sign in size, color, or material at any location where display of the official sign is required or permitted. However, any such varied sign that is displayed in locations where display of the official sign is required must not be smaller in size than the official sign, must have the same color for the text and graphics, and include the same content. 12 CFR § 328.3(b)(4).
(Updated May 13, 2026)
5. Is an IDI required to display the FDIC official sign in a drive-through location?
Answer: Under part 328, if insured deposits are usually and normally received in areas of the premises other than teller windows or stations, the IDI must display the official sign continuously, clearly, and conspicuously in one or more locations in a manner that ensures a copy of the official sign is large enough so as to be legible from anywhere in those areas. 12 CFR § 328.3(b)(2). Because drive-through lanes at IDIs can vary greatly, each IDI should assess their situation and apply the requirements under part 328 as appropriate. For example, bank branches may have one or more drive-through lane(s) with teller windows, deposit drop boxes, or ATMs. Each of these scenarios would be subject to different signage requirements.
(Updated May 13, 2026)
6. In a small bank branch where there is limited space and where deposit and non-deposit products are offered in the same area, can a banker switch between displaying the FDIC official sign and “non-deposit” signage in the same room when discussing different products?
Answer: Yes. In general, if non-deposit products are offered within an IDI’s premises, the space where those products are offered must be physically segregated from areas where insured deposits are usually and normally accepted. The institution must identify areas where activities related to the sale of non-deposit products occur and clearly delineate and distinguish those areas from the areas where insured deposit-taking activities occur.
In limited situations where physical considerations present challenges to offering non-deposit products in a distinct area from deposit products, IDIs must take prudent and reasonable steps to minimize customer confusion. For example, due to limited space, an IDI that offers both deposit and non-deposit products in the same private office and at the same desk, may switch between displaying the FDIC official sign and non-deposit sign when discussing the relevant product to help minimize customer confusion. However, at no time should a non-deposit sign be displayed in close proximity to the FDIC official sign.
(Updated December 2, 2024)
B. Non-Deposit Signs
1. Is the non-deposit sign required to be displayed in the individual offices within IDIs where non-deposit products are offered?
Answer: Yes. Under 12 CFR § 328.3(c)(2), an IDI must continuously, clearly, and conspicuously display the required non-deposit signage at each location within the premises where non-deposit products are offered. If non-deposit products are offered in individual offices, the non-deposit sign should be visible in those offices.
(Updated July 15, 2024)
II. Digital Channels (e.g., Websites or Apps)
A. Placement and Display of Official Digital Sign
1. Are IDIs' websites considered deposit taking channels for purposes of the digital signage requirements?
Answer: Under part 328, the FDIC official digital sign must be displayed on “digital deposit taking channels,” which includes IDIs’ “websites and web-based or mobile applications, that offer the ability to make deposits electronically and provide access to deposits at insured depository institutions.” 12 CFR § 328.5(a). If an IDI’s website is purely informational, with no ability to make deposits or access deposits, it would not be a digital deposit-taking channel.
(Updated July 15, 2024)
2. Can the official digital sign appear only on the IDI’s “homepage” and not on the other web pages that make up the website?
Answer: No. Under part 328, the FDIC official digital sign must be displayed on the (1) initial page or homepage of the IDI’s website or application, (2) login page, and (3) the page or screen where a consumer first initiates a deposit account opening. 12 CFR § 328.5(c).
(Updated May 13, 2026)
3. Where are IDIs required to place the FDIC official digital sign on a bank web page or app to ensure compliance with the requirement that the official digital sign be displayed clearly, continuously, and conspicuously? Can the FDIC official digital sign be placed in the footer?
Answer: Part 328 requires IDIs to display the FDIC official digital sign in a clear, continuous, and conspicuous manner. (See answer II.A.2. above for the applicable pages). The regulation provides explicit examples of FDIC official digital sign placement to assist banks with satisfying the “clear, continuous, and conspicuous” standard including, but not limited to, the homepage of an IDI’s website that continuously displays the FDIC official digital sign near the top of the page and adjacent to the IDI’s name; the login page for an IDI’s mobile application that displays the FDIC official digital sign immediately adjacent to the username and password fields; and the deposit account opening page for an IDI’s web-based application that displays the FDIC official digital sign near the top or center of the page.
The FDIC official digital sign may be placed in other areas of the page or in the footer if displayed clearly, continuously, and conspicuously.
Below is an example of the clear, continuous, and conspicuous display of the FDIC official digital sign near the top of a homepage and adjacent to the IDI’s name:
(Updated May 13, 2026)
4. Can the official digital sign be dismissed once a customer logs in?
Answer: No. Part 328 requires that the official digital sign be displayed “in a continuous manner,” which means it must remain visible on the (1) initial page or homepage of the website or application, (2) login page, and (3) page where consumers first initiate a deposit account opening. 12 CFR § 328.5(c). Part 328 does not, however, require the official digital sign to continue to follow the user as they scroll up or down the screen.
(Updated May 13, 2026)
5. Does the official digital sign need to be linked to the FDIC’s website?
Answer: No. Part 328 does not require the official digital sign to be linked to the FDIC’s website. However, optional versions of the official digital sign that are linked to BankFind and FDIC’s Electronic Deposit Insurance Estimator (EDIE) are available to bankers on FDICconnect, a secure website operated by the FDIC that FDIC-insured institutions can use to exchange information with the FDIC. Bankers can also download the FDIC official digital sign on FDICconnect.
(Updated May 13, 2026)
6. How should IDIs display the FDIC official digital sign on mobile devices with screen resolutions that do not support the ability to display the entirety of the digital sign on one line?
Answer: Generally, the FDIC official digital sign should be displayed as presented (shown below) at 12 CFR § 328.5(b), with no alteration to the text except for color variation as noted in the regulation text.
If the image does not fit a particular device or screen, the official digital sign can be scaled, “wrapped” or “stacked” to fit the relevant screen (shown below).
(Updated May 13, 2026)
7. Does the FDIC official digital sign need to be displayed every time an IDI’s name appears on a page or screen of the IDI’s website or app?
Answer: No. IDIs are not required to display the FDIC official digital sign every time the IDI’s name appears.
(Updated May 13, 2026)
8. Is the official digital sign required on pages where customers may transact with deposits?
Answer: No. The requirement to display the official digital sign on pages where the customer may transact with deposits was removed from the regulation in 2026.
(Updated May 13, 2026)
9. Is an IDI required to display the official FDIC digital sign on a dashboard or portal of an IDI’s website or app after the customer logs into the account?
Answer: No. In general, a “dashboard” or “portal” is an account summary web page or screen on a website or app that typically displays a customer’s financial information regarding various products after logging in. For example, a dashboard may provide an overview of an IDI customer’s checking, savings, mortgage, investment, and retirement account balances. For the purposes of part 328, a dashboard or portal as described here is not an initial or homepage, login page, or a page where a consumer first initiates a deposit account opening. Accordingly, an IDI is not required to display the official FDIC digital sign on such a dashboard or portal.
(Updated May 13, 2026)
10. Where should the official digital sign be placed if the IDI’s app or website does not currently display the IDI’s full name; it only displays the IDI’s logo or a partial name?
Answer: Part 328 provides that an official digital sign continuously displayed near the top of the relevant page or screen and adjacent to the IDI’s name would be considered clear and conspicuous. 12 CFR § 328.5(e)(1).
If an IDI displays its full name, a partial name of the IDI, or the logo of the IDI (or any similar symbol used to identify the IDI) near the top of the page or screen, and continuously displays the official digital sign adjacent to it, this approach would be considered clear and conspicuous.
(Updated May 13, 2026)
11. How should IDIs incorporate the digital sign on mobile devices in accordance with part 328’s requirements while also remaining compliant with the Americans with Disabilities Act (ADA)?
Answer: Part 328 does not supersede or alter the requirements of IDIs to comply with ADA’s digital accessibility rules. As IDIs implement part 328’s requirements, IDIs should take steps to ensure that their web content is fully compliant with other laws and regulations.
(Updated May 13, 2026)
12. Do the FDIC official digital sign requirements apply to downloadable content such as terms and conditions or other digital collateral available via an IDI’s online channels?
Answer: Generally, no. The FDIC official digital sign is required on digital-deposit taking channels, including websites and web-based applications, that offer the ability to make deposits electronically and provide access to deposits. Whether the content is downloadable does not affect whether these requirements apply.
(Updated May 13, 2026)
13. Is an IDI required to display the FDIC official digital sign in the app store where the IDI’s app is available for download?
Answer: No. An IDI is not required to post the official digital sign in the app store where its app is available for download.
(Updated August 16, 2024)
14. Is it permissible to translate the FDIC official digital sign into Spanish or another language other than English, and still be in compliance with part 328?
Answer: IDIs must display the FDIC official digital sign in English, as shown below and specified under 12 CFR § 328.5(b). In addition to displaying the required FDIC official digital sign, IDIs may also display a translation of the official digital sign in another language.
(Updated May 13, 2026)
15. Are sweep accounts considered non-deposit products or uninsured deposit products for purposes of part 328’s digital sign requirement? In other words, should the FDIC official digital sign be displayed on digital channels where customers can transact in sweep accounts?
Answer: The regulation does not require that IDIs display either the FDIC digital sign or non-deposit signage on pages relating to “hybrid products.” Banks typically offer business overnight sweep accounts where money is swept from traditional business deposit checking accounts into investments that are not FDIC-insured. Such sweep accounts are considered “hybrid products” under part 328. 12 CFR § 328.1. However, customer disclosure requirements related to the insurability of sweep accounts apply consistent with 12 CFR § 360.8(e).
(Updated May 13, 2026)
B. Non-Deposit Signs
1. On IDIs’ web pages or apps where IDIs are required to display the non-deposit sign, where should the non-deposit sign be displayed?
Answer: An IDI must clearly, conspicuously, and continuously display a non-deposit sign on each page primarily dedicated to advertising or providing information about, or access to, one or more non-deposit products.
An example of clear and conspicuous placement is to place non-deposit signage towards the bottom of the page in a manner that distinguishes the text of the non-deposit signage from the smallest text on the page using, for example, bold or larger text, or surrounding the signage with a text box. 12 CFR § 328.5(e)(4).
(Updated May 13, 2026)
2. How can an IDI satisfy the requirement to display a “one-time notification” before a customer accesses a third-party website?
Answer: If an IDI’s website or mobile application provides access to a third party platform that offers non-deposit products, the IDI must provide a one-time per web session notification before a customer who has logged in leaves the IDI’s platform to access the third party platform. The one-time notification could include, for example, an IDI using a “pop-up,” “speedbump,” or “overlay” that appears before the IDI’s customer may initially access the third party’s online platform. The notification may be dismissed either automatically after three seconds, manually by the customer, or a combination of these two methods.
The notification must clearly and conspicuously indicate that the third party’s non-deposit products: are not insured by the FDIC; are not deposits; and may lose value. 12 CFR § 328.5(d)(2)(ii). As with all of part 328’s signage requirements, IDIs may, but are not required to, include additional disclosures in the notification that may help prevent consumer confusion, including, for example, that the IDI customer is leaving the IDI’s website.
(Updated May 13, 2026)
3. Does the requirement for a non-deposit “one-time notification” before a customer accesses a third-party website need to appear twice in the same session, if the customer clicks on the same link twice?
Answer: No. If an IDI customer who is logged into an IDI’s digital deposit-taking channel (such as an IDI’s website and app) clicks on a hyperlink that takes them to a third-party's website and then the customer clicks on the same hyperlink again in the same session, the IDI would only be required to provide the one-time notification the first time the customer clicks the link, and not each subsequent time that the customer clicks on the same link in the same session.
On the other hand, the notification should be given twice during the same session if a consumer clicks on a link to access a third-party website and then in the same session clicks on a different link that takes them to a different third party’s website.
(Updated August 16, 2024)
4. How are affiliated entities treated for the purpose of complying with the requirement under 12 CFR § 328.5(d)(2) for a “one-time notification” for bank customers related to a third party’s non-deposit products?
Answer: For the purposes of 12 CFR § 328.5(d)(2), the FDIC views affiliated entities as third parties. Accordingly, if an IDI’s website or mobile application provides access to an affiliate’s platform that offers non-deposit products, the IDI must display a “one-time” notification before a logged-in bank customer may leave the IDI’s platform to access the affiliate’s platform. For additional information, see 12 CFR § 328.5(d)(2) and the response to question II.B.2 above.
(Updated May 13, 2026)
5. Would displaying a shortened version of the Interagency Statement on Retail Non-Deposit Investments disclosure satisfy the requirements of the FDIC non-deposit sign?
Answer: Yes. A shortened version of the Retail Non-Deposit Investments disclosure (“not FDIC insured; no bank guarantee; may lose value”) can be substituted for the non-deposit sign (“are not insured by the FDIC; are not deposits; and may lose value”), as long as the language is displayed clearly, conspicuously, and continuously on each webpage primarily dedicated to advertising or providing information about, or access to, one or more non-deposit products.
(Updated May 13, 2026)
6. If an IDI identifies instances on its website where a consumer could be confused about a product offering or other issues, does the IDI have flexibility to provide additional clarifying information to consumers?
Answer: Yes. An IDI may provide additional or supplemental clarifying disclosures to consumers on its digital channels. Part 328 expressly provides IDIs with the latitude to display additional disclosures through subsection 12 CFR § 328.5(f), which provides that the signage requirements for digital deposit taking channels do not limit IDIs’ ability to display signage and disclosures in addition to those required by part 328. Examples of additional disclosures on IDIs’ digital deposit-taking channels include, but are not limited to: “FDIC insurance availability on this page only applies to deposit accounts at [IDI name]” and “[IDI name] deposit products are FDIC insured.”
(Updated May 13, 2026)
7. When disability insurance or credit insurance is added to a loan, such as a car loan, does the bank need to post the “not FDIC insured” sign?
Answer: Generally, FDIC staff has viewed credit life insurance as well as disability insurance as part of the offering of credit. Under 12 CFR § 328.1, the definition of “non-deposit product” does not include “credit products,” which means the non-deposit sign is not required when an IDI offers credit products.
(Updated May 13, 2026)
8. Is an IDI required to display the non-deposit sign on a bank’s navigation menu near a link to a non-deposit product page, and provide a one-time notification, such as a pop-up screen?
Answer: Generally, no. Non-deposit signage is only required on pages or screens primarily dedicated to advertising or providing information about, or access to, non-deposit products. A page would not meet this standard solely because it includes a navigation menu that includes links to a non-deposit product page.
However, for logged-in bank customers, an IDI would only be required to provide a one-time notification, such as a “pop-up,” “speedbump,” or “overlay,” if the link offers access to non-deposit products from a non-bank third party’s online platform. 12 CFR § 328.5(d)(2). The IDI may, but is not required to, include additional disclosures in the notification that may help prevent consumer confusion, including, for example, that the IDI customer is leaving the IDI’s website. See answer II.B.2 for additional information regarding the “one-time notification” requirement.
(Updated May 13, 2026)
C. Use of Advertising Statement on Digital Channels
1. Should IDIs include the “Member FDIC,” “Member of FDIC,” or “FDIC-Insured” advertising statement on every page of their digital platforms?
Answer: The advertising statement (e.g., “Member FDIC”) must be displayed on advertisements, consistent with 12 CFR § 328.6. It is not intended to overlap with the official digital sign, and the advertising statement is not required on web pages where an IDI displays the official digital sign, such as the bank’s homepage. However, an IDI is not prohibited from displaying the advertising statement on a page that also includes the official digital sign, so long as the use of the advertising statement on that page is otherwise consistent with the official advertising statement requirements in 12 CFR § 328.6.
(Updated July 15, 2024)
2. If a customer clicks on a hyperlink on an IDI’s web page to get marketing information about specific deposit products, would such a marketing page that a customer subsequently views require the FDIC official digital sign?
Answer: Advertising pages (i.e., commercial messages, in any medium, designed to attract public attention or patronage to a product or business) must adhere to the requirements of 12 CFR § 328.6, which requires the inclusion of an official advertising statement, either “Member of the Federal Deposit Insurance Corporation,” or a short title of “Member of FDIC,” “Member FDIC,” “FDIC-insured,” or a reproduction of the FDIC’s symbol. IDIs are not required to display the official FDIC digital sign on advertising pages.
(Updated May 13, 2026)
3. Can the FDIC provide a translation of the new “FDIC-Insured” optional short title of the official advertising statement?
Answer: Under the regulation, IDIs have the option to use “FDIC-Insured” as a short form of the official advertising statement to satisfy advertising statement requirements under 12 CFR § 328.6. Under part 328, a non-English equivalent of the official advertising statement may be used in any advertisement, provided that the translation has the prior written approval of the FDIC.
Below please find the translation of the optional short title, “FDIC-Insured,” in 26 non-English languages that IDIs may use as the official advertising statement pursuant to part 328. For convenience, the FDIC is also providing the 26 non-English translations of the other optional short titles “Member FDIC” and “Member of FDIC.”
(Updated May 13, 2026)
Translation of “FDIC-Insured”
| Language | Translation |
|---|---|
| Arabic | FDIC مؤمَّن عليه من قبل |
| Bengali | FDIC বীমাকৃত |
| Burmese | FDIC တွင်အာမခံထားရှိသည် |
| Chinese (Traditional – ZHHK) | FDIC 承保 |
| Chinese (Simplified – ZHTW) | FDIC 承保 |
| Dari | بیمه شده FDIC |
| Haitian Creole | FDIC Asire |
| French (France) | Assuré par la FDIC |
| German | FDIC-versichert |
| Greek | Με ασφάλιση FDIC |
| Gujarati | FDIC દ્વારાવીમાથી આરક્ષિત |
| Hindi | FDIC बीमित |
| Italian | Assicurato FDIC |
| Hmong | Muaj Kev Pov Hwm Los Ntawm FDIC |
| Japanese | FDIC 預金保護対象 |
| Korean | FDIC 보험에 가입됨 |
| Pashto | د FDIC لخوا بيمه شوی |
| Polish | Ubezpieczony przez FDIC |
| Portuguese (Brazil) | Segurado pela FDIC |
| Russian | Застрахован FDIC |
| Ukrainian | Застрахований FDIC |
| Spanish | Asegurado por la FDIC |
| Swahili | Imelipiwa bima na FIDC |
| Tagalog (Philippines) | Nakaseguro sa FDIC |
| Vietnamese | Được FDIC Bảo Hiểm |
| Urdu | FDICسےانشورنس یافتہ |
Translation of “Member FDIC”
| Language | Translation |
|---|---|
| Arabic | FDIC عضو |
| Bengali | FDIC সদস্য |
| Burmese | FDIC မန်ဘာအဖွဲ့ဝင် |
| Chinese (Traditional – ZHHK) | FDIC 成員銀行 |
| Chinese (Simplified – ZHTW) | FDIC 成员银行 |
| Dari | عضو FDIC |
| Haitian Creole | Manm FDIC |
| French (France) | Membre de la FDIC |
| German | Mitglied FDIC |
| Greek | Μέλος FDIC |
| Gujarati | FDIC સભ્ય |
| Hindi | सदस्य FDIC |
| Italian | Membro FDIC |
| Hmong | Tswv Cuab rau FDIC |
| Japanese | FDIC 加盟銀行 |
| Korean | FDIC 회원 |
| Pashto | FDIC غړی |
| Polish | Członek FDIC |
| Portuguese (Brazil) | Membro da FDIC |
| Russian | Член FDIC |
| Ukrainian | Член FDIC |
| Spanish | Miembro FDIC |
| Swahili | Mwanachama wa FDIC |
| Tagalog (Philippines) | Miyembro ng FDIC |
| Vietnamese | Thành Viên FDIC |
| Urdu | FDIC ممبر |
Translation of “Member of FDIC”
| Language | Translation |
|---|---|
| Arabic | ﻋﺿو FDIC |
| Bengali | FDIC এর সদস্য |
| Burmese | FDIC ၏မန်ဘာအဖွဲ့ဝင် |
| Chinese (Traditional – ZHHK) | FDIC 成員銀行 |
| Chinese (Simplified – ZHCN) | FDIC 成员银行 |
| Dari | ﻋﺿو FDIC |
| Haitian Creole | Manm FDIC |
| French (France) | Membre de la FDIC |
| German | Mitglied der FDIC |
| Greek | Μέλος της του FDIC |
| Gujarati | FDIC ના સભ્ય |
| Hindi | FDIC का सदस्य |
| Italian | Membro della FDIC |
| Hmong | Tswv Cuab ntawm FDIC |
| Japanese | FDIC 加盟銀行 |
| Korean | FDIC 회원 |
| Pashto | د FDIC ﻏړی |
| Polish | Członek FDIC |
| Portuguese (Brazil) | Membro da FDIC |
| Russian | Член FDIC |
| Ukrainian | Член FDIC |
| Spanish | Miembro de la FDIC |
| Swahili | Mwanachama wa FDIC |
| Tagalog (Philippines) | Miyembro ng FDIC |
| Vietnamese | Thành Viên của FDIC |
| Urdu | FDICکا ممبر |
4. When does an IDI need the FDIC’s consent to use non-English translations for the advertising statement and how is consent obtained?
Answer: An IDI does not need FDIC’s consent or prior approval to use any of the translations provided above in II.C.3. IDIs requesting to use a different translation may send an email with their request to DepositInsuranceBank@FDIC.gov.
(Updated May 13, 2026)
D. Automated Teller Machines or Like Devices
1. When implementing new official digital signage on ATMs, are IDIs required to remove existing physical signs, or can both types of signage be displayed simultaneously?
Answer: IDIs are not required to take down physical FDIC official signs attached to ATMs. If an IDI’s ATM or like device either (1) was placed into service before April 1, 2027 or (2) does not permit customers to transact with non-deposit products, the IDI has the option of meeting the signage requirement by either (1) displaying the FDIC official digital sign electronically on the initial ATM screen or (2) displaying the physical official sign by attaching or posting it to the ATM. 12 CFR § 328.4(c).
(Updated May 13, 2026)
2. If an IDI’s ATM accepts deposits but does not permit customers to transact with non-deposit products, on what pages or screens are IDIs required to post or display official FDIC signs?
Answer: For ATMs or like devices that (1) are currently in service, or that will be put into service before April 1, 2027, or (2) do not offer access to non-deposit products, IDIs may comply with the official sign requirement in one of two ways.
The first option is to post or attach the physical official FDIC sign (as described in 12 CFR § 328.2) on the ATM.
The second option is to display the FDIC official digital sign as described in § 328.5 on the ATM’s initial screen. Under 12 CFR § 328.4(b), the “initial screen” does not include a screen saver or an advertisement for products, services, or events on the screen of an idle ATM. The “initial screen” is the screen that is displayed before an IDI’s customer inserts a debit card or other credentials to access the device (sometimes referred to as a “welcome screen”).
(Updated May 13, 2026)
3. For an IDI’s deposit taking ATM, is the IDI required to post non-deposit signage when a debit card from another institution is used to log into an ATM?
Answer: IDIs are required to display non-deposit signage on the first page or screen displayed when an IDI’s customer initiates a transaction with a non-deposit product. This requirement does not apply to a non-customer, such as a user logging into their account at another institution using a debit card issued by that other institution. 12 CFR § 328.4(d).
(Updated May 13, 2026)
4. Is the FDIC official digital sign required on all ATMs, and if the sign is required, must it be displayed on all screens?
Answer: Except as described below, an IDI’s ATM or like device that receives deposits for an IDI must clearly, continuously, and conspicuously display the FDIC official digital sign on the initial screen of such an ATM or like device. For purposes of this requirement, a screen saver—such as an advertisement for products, services, or events on the screen of an idle ATM—is not considered the “initial screen.”
If the ATM does not offer access to non-deposit products, or if the ATM was placed into service before April 1, 2027, part 328 provides flexibility to meet the signage requirement, allowing the IDI to display the physical FDIC official sign by physically attaching it to the ATM instead of using the electronic sign on its initial screen.
(Updated May 13, 2026)
5. If an ATM allows transfers of funds between deposit accounts but does not accept cash or check deposits, is the ATM subject to the sign requirements described in section 328.4?
Answer: No. The sign requirements in section 328.4 only apply to IDIs’ ATMs and other remote electronic facilities that receive deposits.
(Updated May 13, 2026)
6. Where a non-bank owns and operates a bank-branded ATM (e.g., displays bank sign on top of the machine, bank’s name and logo is displayed on screen, etc.), is it permissible under part 328 for the ATM to display the FDIC official digital sign?
Answer: It depends. The FDIC has explained that display of the FDIC official digital sign by non-bank third parties is generally improper because display of the sign would imply that the non-bank is FDIC-insured. See 89 Fed. Reg. 3504, 3511-12 (Jan. 18, 2024). However, staff believes use of the FDIC official digital sign by a bank on non-bank owned, bank-branded ATMs does not raise this concern where the ATM includes a sufficient amount of a bank’s branding to clearly imply that the customer is doing business with the bank (e.g., there’s a bank sign on the ATM and the bank’s name and logo is on the ATM screen). In such cases, staff believes the FDIC official digital sign may be displayed on the ATM in a manner consistent with section 328.4.
(Updated December 2, 2024)
E. Social Media
1. Are IDIs required to post the FDIC official digital sign on its social media advertisements?
Answer: No. IDIs are not required to display the FDIC official digital sign on its social media advertisements. IDIs should ensure that social media advertisements are compliant with the official advertising statement requirements contained in 12 CFR § 328.6.
(Updated May 13, 2026)
III. Advertising for Non-Deposit Products
1. In marketing materials that feature safe deposit boxes or credit products alongside insured products like checking accounts, should IDIs include a disclosure stating that these products are not FDIC-insured?
Answer: For the purposes of part 328, safe deposit boxes and credit products are excluded from the definition of “non-deposit product.” Therefore, there is no requirement under part 328 for an IDI to include such a disclosure in marketing material for these products.
(Updated July 15, 2024)
IV. Implementation Information
1. If an IDI took all necessary actions to ensure it complied with the part 328 final rule adopted in 2023, would that IDI also be in full compliance with the part 328 final rule adopted in 2026?
Answer: For the most part, IDIs that have already complied with the signage requirements of the 2023 final rule would also be in compliance with the 2026 final rule. However, as noted in the preamble to the 2026 final rule, one possible exception is that IDIs are expressly required under the 2026 rule to display the FDIC official digital sign on a page or screen where the consumer first initiates a deposit account opening, whereas the 2023 rule was unclear as to whether the broader requirement to display the sign on “pages where a customer may transact with deposits” included deposit account opening pages.
(Updated May 13, 2026)