The FDIC has published logo updates, including a new digital sign to be displayed at deposit taking ATMs. The digital sign must be displayed ".... clearly and conspicuously in a continuous manner..."

We currently have Member FDIC displayed on the opening screen, but once the user starts the transaction, the screen changes to ask questions about the withdrawal (amount, account, etc.). I'm not sure how we can support the transaction and display the digital sign continuously.

Any ideas?

Only for those devices put into service after January 1, 2025, I thought?

For a machine put into service before 1/1/2025 that does not provide access to nondeposit products, you have two options. You can affix an FDIC Official Sign (like the ones at your teller stations) to the front of the machine), or use the new official digital sign on the home screen and each transaction screen or screen relating to deposits. You don't have to do both. The "stick the official sign on the enclosure" option remains available after 1/1/2025.

If you go the route with the FDIC official sign stuck on the front of the ATM, you will have to keep an eye on it and replace it if it it's vandalized so that it is no longer "clear and conspicuous."

You can hang a physical sign, if it's an existing ATM. That's my current plan.
328.4 (b) ATMS or like devices that do not offer access to non-deposit products....
(1) Displaying the physical official sign as described in 328.2 on the automated teller machine, subject to paragraph (f); OR
(2) Displaying the FDIC official digital sign....

Relying just on "Member FDIC" on your first screen will not cut it as of New Year's Day 2025.

If the ATM does not provide access to nondeposit products, must the new official digital sign also be on each transaction screen or screen relating to deposits? Or, must the digital sign be on each transaction screen or screen relating to deposits only if the ATM provides access to nondeposit products?

If you don't provide access to nondeposit products, and your ATM is placed in service before 1/1/2025, you can comply by just sticking the FDIC official sign on the face of the ATM. You don't need to include the official digital sign on any screens. You will need to check the ATM periodically to make sure that stuck-on sign is still there and still legible. If it's been removed or vandalized so it's no longer clear and legible,. You will have to replace it promptly, so get a supply of the signs for backup.

If you put the machine in service before 1/1/2025, you can go the other route and use the official digital sign. It will have to appear conspicuously and continuously near the top of the "home" screen, near the bank's name. It also has to appear on each transaction page or screen relating to deposits.

If you put the ATM into service on or after 1/1/2025, you have to go the official digital sign route.

This is laid out pretty clearly in new section 328.4, which you can see HERE.

Has anyone found an official downloadable image file for the new FDIC official digital sign? I still can't find it on the FDIC's online catalog. While the final rule provides specifications for creating the new sign, it doesn't end up matching exactly to the image included in the final rule.

does the gold sign stay on desks or is that changing as well?

Has anyone come across an implementation of the digital signage requirements thus far or any examples besides the logo itself?

You mean an example of some bank using it?

Yes

Not that I have seen.

I have a question about the ATM sign. What happens if we post the FDIC sign on the ATM and it gets ripped off and we don't know about it right away and someone complains about it to the FDIC, will there be some sort of grace period to get a new sign in place?

We require our branches inspect the ATMs on a daily basis. This includes making sure all signs are intact. Have extra signs in stock.

If you update your ATMs to display the FDIC's new digital official sign on appropriate screens, and otherwise comply with the new rules under Part 328 section 328.4 (but not 328.4(b)(1)), you can remove those weather- and vandalism-susceptible FDIC stickers and not worry about them any more.

I have now come across a few banks displaying the official digital sign, thought I would share...

https://www.peoplesstatebank.com/
https://www.statebankfinancial.bank/
https://www.bankoftescott.com/

I have read the rule a couple of times and want to make sure I am not interpreting (inferring what I want) so here is my question.... If our ATMs do NOT accept any deposits are we absolved from the new signage requirement?

Yes, if your ATMs are all placed in service before 1/1/2025. For these machines, you can put a physical official FDIC sign on the machine, with the understanding that you have to keep replacing it if it is vandalized and no longer clearly and continuously displayed, or you can upgrade/reprogram the machines to display to new FDIC official digital sign as required by new section 328.4(c) on its home page or screen and on each transaction page or screen relating to deposits.

If you put an ATM (or similar equipment) into service on or after 1/1/2025, you must use the official digital sign on it. You cannot use the old method of sticking the same sign displayed at teller windows on the machine.

How long a grace period will we have to replace/fix the vandalized sign on the ATM?

The regulation doesn't provide a "grace period." I suggest you have a backup inventory of replacements for as long as you use the "grandfathered" machines that were put into service before 1/1/2025, and that checking the sign be part of the regular servicing of the ATM.

still looking for clarification...the above websites where the banks have already made the FDIC change - the first one listed has a Wealth Management Tab - unless i missed it - is it correct in not having the not, not, may statement on these pages?

When looking at the websites mentioned above, one of them is not using the specified color format. Do we need to follow that?

Good Afternoon,

In re-reading 328.4(a) (see below), I am still questioning if this applies to my situation since my bank's ATMs do not and will not accept deposits. It is only a dispenser of cash.

Scope. This section governs signage for insured depository institutions' automated teller machines or other remote electronic facilities that receive deposits.

What am I missing?

It is my understanding that if your ATM does not accept deposits or offer access to non-deposit products, you do not have to use the digital sign.

Most if not all the questions in this thread were answered in the FDIC seminar yesterday. I highly recommend attending the next sessions that will be offered. Helped me a lot. I'm putting together my action plan and have a much better understanding of the requirements.

We are waiting on our vendor to update us on how they will be adding the Digital Official Sign to our mobile app. There can be no wrapping of the text. It can be scaled proportionately, but must be legible.

Are you referring to the one with the white logo and text?

The final rule reads: If the official FDIC digital sign in these colors would be illegible due to the color of the background, the final rule requires
the “FDIC” and the one line of smaller type to the right of “FDIC” to both be displayed in white (hexadecimal color code #FFFFFF).

Technically, I don't think the "colors would be illegible due to the color of the background" using the original image here but there is the above that allows for the white logo and text.

Thanks for the clarification!

While there is not a NOT, NOT, May statement on that page, there are no non-deposit products touted there. Each of the pages linked on that page that include non-deposit products do have NOT, NOT, May statements, however, and I noticed there is no mention of FDIC membership on those pages.

As for the white text against dark red background on one of the other sites, I think it is more legible than navy blue and black against the dark red, so I think it passes muster.

Did anyone who attended the FDIC webinar on the 30th of May get any feedback from the FDIC on how to make the FDIC official digital sign work on a bank's smartphone banking app?

I obviously did not read your earlier post carefully, since you clearly said your ATMs do not accept deposits and will not do so.

As noted, section 328.4 only applies to ATMs and similar machines that accept deposits. So there is no FDIC signage requirement at all for an ATM or similar machine that does not accept deposits.

Unless, of course, the FDIC changes the rule at some later date.

Okay John - I nearly spit my coffee all over my laptop laughing. That was good. I read a lot of snark into it.

Moi? Snarky? Guilty as charged!

On 5/31 I sent an email to the address provided during the webinar to receive the official digital sign. I have had no response. Has anyone else received a response. I also checked on FDICconnect and I could not locate it in the catalog. Anyone have any luck with either?

I sent an email through FDIC connect, and I have received the digital sign.

Thanks! I will try that route!

Okay - I feel pretty dumb asking this, but how do you send an email through FDICConnect? I log on all the time to get to EFX and Consumer Complaints, and I can get to the catalog, but I don't see where to send an email through the system itself.

Took me a minute too. There is a Contact Us. I completed it and received an email that said:

Good afternoon,

Thank you for contacting the FDIC regarding your recent inquiry on 6/10/2024.

Your inquiry was forwarded to the appropriate subject matter expert for handling. Please be on the look out for a follow up email regarding your inquiry.

If you have any other questions or concerns, please contact our toll-free 1-877-ASK-FDIC (1-877-275-3342).

Should you need to contact us again regarding this matter, your reference number 01742278 will expedite our response.

Sincerely,

FDIC Contact Center
Division of Administration
Federal Deposit Insurance Corporation

I did receive it within a couple of weeks. That surprised me.

We actually received a response to our original email request: Requested information on 5/31, received a response on 6/11.

Any thoughts on ATM receipts? Our marketing team, wasting no opportunity, has an ad preprinted on the back of the receipt tape. My first reaction is that this is paper, not digital, and so will not need an update. But I want to make sure I am not missing some finer point about displaying Member FDIC on an ATM receipt.

Well, there is nothing in new § 328.6(d) that specifically exempts receipts, whether they are receipts for deposits made in person or receipts from an ATM. I think you can make a case for including them in 328.6(d)(2) as bank supplies, however.

That said, I have to wonder why anyone would argue against including "Member FDIC" or "FDIC-insured" (the new "short title") with the ad printed on the back of the receipts. It can't be a matter of an increased cost to include it. On the other hand, what does the ad say? If that same ad were printed in a newspaper, would it need to have the FDIC short title included? Do the ads rotate on the roll of receipt paper (for example, a series of 6 short ads that are printed in sequence on the back of 6 receipts, then repeated for the full length of the receipt roll).

And at the end of this response, I'll suggest that it is a very low-risk issue whether it's included in those ATM receipt ads.

Has anyone been able to successfully find on FDIC connect where to download the digital version?

Our ATMs only provide balance information, allow transfers between deposit accounts, and have withdrawal capabilities. Would the transfer capability be considered a deposit-taking channel which requires the FDIC sign to be displayed?

I am wondering the same thing after the last FDIC webinar and answer to the ATM Question #2 in the FDIC's Q&As.

I emailed the FDIC directly and they sent it to me.