Like many other financial institutions, we include the new FDIC digital logo to the header of the home page on our website. Marketing has recently added a very generic heading about non-deposit investment products about halfway down the page with a "Learn More" button directed to the NDIP page (which does not include the FDIC logo).

Should this section be removed from the home page since the FDIC digital logo is at the top? Or do we need to add the Not-Not-May language next to the investments heading?

I believe your generic NDIP heading/section can likely remain on your home page. The "non-deposit signage", as the FDIC calls it, can be displayed on the same page as the official FDIC digital logo/sign, as long as the two are not displayed in close proximity to each other or in some way that is likely to cause confusion. Half way down the page would seem to be fine. They've advised not to include it when there's a navigation bar/menu with a link to NDIP pages located right below the bank's name/logo because the two signs would likely end up being right on top of each other.

In the past, many institutions used the Not-Not-May language only in the footer of a relevant webpage. The updated rule and FAQ says that if you're only planning to put it in the footer, that is no longer sufficient. The Not-Not-May language can certainly still be used instead of the new "non-deposit signage", but either way it has to be displayed in a clear, conspicuous, and continuous way, near where "access" to a non-deposit product is provided, and on each page related to the non-deposit product.

I've found that the "access" to a non-deposit product is a bit more difficult to define, which gets to the heart of your question. Is a generic NDIP heading with a link to more info enough to require the language? I would err on the side of caution and yes, include it.

My approach is to include the new "non-deposit signage" or the old NDIP language directly in any section that discusses NDIPs, directly next to a link that takes you to a NDIP product page, and obviously on all of the actual NDIP product pages themselves. I think that approach would be more than enough to show a good faith effort to comply with the requirements of the updated rule.