We have added NMLS numbers and a short summary about our FI to our business cards, but we do not have Member FDIC or EHL logo on our cards. Is this an issue?

It depends what is in the "short summary." If the summary promotes either 1) deposit products and services or 2) non-specific banking products and services (see the citation below), then yes, the FDIC membership rules apply because the business card technically becomes an advertisement under the FDIC advertisement rules.

From the FDIC advertisement of membership rules:
"(c) Use of official advertising statement in advertisements--(1) General requirement. Except as provided in § 328.3(d), each insured depository institution shall include the official advertising statement prescribed in § 328.3(b) in all advertisements that either promote deposit products and services or promote non-specific banking products and services offered by the institution. For purposes of this § 328.3, an advertisement promotes non-specific banking products and services if it includes the name of the insured depository institution but does not list or describe particular products or services offered by the institution. An example of such an advertisement would be, "Anytown Bank, offering a full range of banking services."

Also, if the "short summary" includes a statement about consumer mortgages, then the EHL rules would apply.

So just the NMLS number would not require Member FDIC or EHL logo.
However a message indicating we have X offices to serve you and want you to bank with us would require Member FDIC?
Would the message above an MNLS number require EHL logo?

What do you mean by "short summary about our FI ".

The MNLS number does not trigger the EHL logo as it doesn't promote home loans.

Correct, the NMLS is not a trigger for either.

It depends on the specific wording of the message, but probably as you appear to be promoting non-specific products and services.


Again, it depends on the actual message, but if there isn't a mention of home loans then the EHL requirements aren't triggered.

We are about to order all new business cards for our employees do to a change in our website name. The marketing department is asking me if we need to include the Member FDIC language on our business cards. I don't think we are required to include it. Am I wrong on this? Would this be considered an advertisement for our bank that we would need to include it?

It depends what text is included on the business card. A business card won't typically need Member FDIC, but could if it promotes either 1) deposit products and services or 2) non-specific banking products and services - which would be the triggers to make the business card an "advertisement." Do your cards say anything like "offering a full range of banking services" or something similar?

I wouldn't sweat it. IMO, business cards are not advertisements even if they say something like "see me for all of your financial needs." I've never seen or heard of an examiner going after this in my 30 years of being an examiners, banker and consultant.

Adam has given you the technical answer and David has offered a practical answer. I'll simply suggest that business cards aren't a big item for the FDIC's examiners' scrutiny.