REMINDER on FDIC Part 328 changes effective May 1

May 1, 2025 — three days from today — is the required compliance date for most of the changes made by the FDIC to subpart A of its Part 328 regulation, "FDIC Official Signs and Advertising Requirements, False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC’s Name or Logo." The compliance date for new sections 328.4 and 328.5, which involve the display of the FDIC's new official digital sign on an insured depository institution's (IDI's) digital channels and on ATMs and similar devices was postponed to March 1, 2026.

The provisions for which compliance is required by May 1, 2025, include:

• Additional requirements and options for displaying the current FDIC official sign in premises where deposits are received (§ 328.3)
• Signage requirements relating to the offering of non-deposit products (§ 328.3)
• Requirements to keep areas where non-deposit products are offered separate from those where deposit products are offered and received (§ 328.3)
• An added "short title" — "FDIC-Insured" — that can be used in advertisements in lieu of the official advertising statement (§ 328.6)
• A prohibition on using the official advertising statement or a short title like "FDIC-Insured" in ads for non-deposit products (§ 328.6)
• Perhaps most importantly, there is a new requirement that IDIs have written policies and procedures for compliance with Part 328 (§ 328.8)