WASHINGTON – The FDIC has signed off on a proposal to overhaul how banks display its official digital sign and warnings on non-deposit products.
The rule aims to streamline requirements for where and how the FDIC sign appears—whether on websites, mobile apps, ATMs, or other digital deposit-taking channels—making it clearer for consumers and simpler for banks to comply, the agency said.
The proposed changes are intended to revise requirements adopted in a 2023 final rule that, among other things, established the FDIC official digital sign and required signage for ATMs and digital banking channels. The proposal would focus display requirements for the FDIC official digital sign and the non-deposit sign on the screens and pages where signage would be most relevant for consumers, the FDIC said.
Comments on the proposed rule will be accepted for 60 days after publication in the Federal Register.
Sullivan & Cromwell pointed out the proposed rule provides additional flexibility with respect to requirements regarding the “color, font, and size” when displaying the FDIC official digital sign. Second, the proposed rule simplifies the signage requirements for digital deposit-taking channels by:
- Requiring the display of the FDIC official digital sign on a depository institution’s initial page or homepage of its website or application, login page and the screen where the consumer initiates a deposit account opening, and not on its “landing page” or on pages where the consumer may transact with deposits.
- Requiring the display of non-deposit signage on all pages and screens that are primarily dedicated to one or more non-deposit products, and not on pages or screens with incidental references to such products.
- Providing a non-exhaustive list of examples of placements of the FDIC official digital sign and non-deposit signage that would meet the requirement in the 2023 final rule that the depository institutions “clearly, continuously, and conspicuously” display such signage.
- Modifying the requirement that a depository institution must ask a consumer to dismiss a notification when the consumer moves from a depository institution website to a non-bank page via hyperlink, also allowing for the notification to be dismissed automatically after a minimum of three seconds.
Sullivan & Cromwell said the proposed rule revises the signage requirements with respect to ATMs by:
- Requiring the display of the FDIC official digital sign on only the initial screen of an ATM.
- Allowing depository institutions to choose to display the physical FDIC official sign on all ATMs placed into service prior to Jan. 1, 2027 and all ATMs, regardless of when placed into service, that do not allow customers to transact with non-deposit products.
- Clarifying that only ATMs and other devices that permit depository institution customers to transact with non-deposit products are required to display the non-deposit signage “clearly, continuously, and conspicuously” on each transaction page relating to non-deposit products.