We are ordering a banner in which local football teams will run through to start the the game. The banner will have the bank's name on it but it will not advertise any products. My understanding is that since we aren't advertising a product and the banner has just our name on it - the FDIC logo is not required. Is my understanding correct on this?

Thanks.

Due to the change in the FDIC requirements effective last November, I believe that it would require the FDIC Official Advertising Statement.
According to the new definition of advertisement it means "a commercial message, in any medium, that is designed to attract public attention or patronage to a product or business" so its coverage is broad. The banner, I believe, would be attracting public attention to your business. Also I believe that it would be promoting "non-specific banking products and services offered by the institution." I take that statement as even if you do not advertise a product at all, just your bank or FI name, it needs it.

Ofcourse I may be following the wording of Sec. 328.3 Official advertising statement requirements to strictly.

Actually, Noah, I agree with you. I just want to emphasize what Noah said: "I believe that it would require the FDIC Official Advertising Statement."

The FDIC's logo is not required on this or any other advertisement. All you need are those two little words, "Member FDIC."

If it's not on the banner for the first time you have it torn to shreds by the thundering hordes, don't sweat it. It's a very low-risk problem. Just get it on the rest of the banners, even if you have to use a Magic Marker. It doesn't have to be legible from the last row of that Texas-sized stadium.

John - the new banners they use are plastic break-apart. You put them back together and use them over and over. I used to be on our local booster club where we ordered things like that. So It would be best to make sure that it is on the banner when ordered.

It costs nothing or next to nothing to include it. But it's also a very low-risk technical violation if you forget to include it on something like these banners.