Answer:
Answer by David Dickinson:I believe you should. You raise an interesting point about the hold time. I have always suggested that you "periodically" mention "Member FDIC." Maybe once following every product promotion or every 30 seconds or so. I don't think an examiner's going to get too excited as long as you mention "Member FDIC" occasionally.
Answer:
Answer by John Burnett:If you take a look at the FDIC's membership advertising rule, in particular at Section 328.3, you'll see there are a number of ways for you to say "Member FDIC." You can describe a deposit product as FDIC-insured. You can state that your bank is a member of the Federal Deposit Insurance Corporation, etc. Varying how you get that message across in your "ads on hold" tape can make it sound more professional and less like you're trying to salt in "Member FDIC" every 30 seconds or so (even if you are). Do make sure you omit the mention of "Member FDIC" in any message that's about non-deposit investment products. In fact, you may need to include with those "mentions" the short disclaimer about the product not being insured, etc.
Oh, about the 30-second intervals. There's nothing magic about that number. And please, don't let it confuse you. The "30-second" exemption from the FDIC's rule on use of its "official advertising statement" only applies to TV and radio ads of 30 seconds or less.
First published on BankersOnline.com 7/02/07
print
share