If we have a link through our website that directs people to a 3rd party vendor to open accounts online, would that page need the updated FDIC Insurance requirements, or would they be exempt? The most recent FDIC webinar on this showed under exemptions "Accesses an embedded 3rd party payment platform after login into their bank's website to initiate payments or move funds out of the bank." The consumer would be able to utilize a different account to fund their new account opened through this platform.
Personally, I think the question is, can they make the initial deposit through there. If they are able to set up an ACH deposit to the new account on that website, you have a deposit taking channel and it should have the logo.
Only IFIs have to include the FDIC official digital sign on their websites. A third-party vendor that provides a channel for someone to create a deposit to an account at your IFI is not permitted to show the FDIC official digital sign or any other sign suggesting affiliation with or membership in the FDIC unless it happens to also be an IDI.
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