The FDIC seeks to avoid overburdening financial services providers with regulations regarding its logo after assessing market feedback and implementation issues.
On August 19, 2025, the Federal Deposit Insurance Corporation (FDIC) board of directors approved a proposed rule (the Proposal) that would amend signage requirements for insured depository institutions’ banking channels, including digital and online banking. The Proposal seeks to revise a 2023 rulemaking that required stricter signage and advertising standards for FDIC regulated entities.
The Proposal reflects the regulatory approach of the Trump administration, which prioritizes technological innovation, business development, and capital formation, while seeking to reduce what is viewed as overly prescriptive and burdensome regulations.
The 2023 Advertising Rule
The FDIC’s mission to maintain public confidence in the nation’s financial system includes the authority to prescribe rules and regulations regarding how insured depository institutions display the FDIC logo and how to use an official advertising statement (commonly, “Member FDIC”) when promoting deposit products and services.
The FDIC’s rule on the matter, 89 FR 3504 (Jan. 18, 2024) (the Advertising Rule), was intended to update regulations regarding the FDIC’s official sign and advertising statement to address an evolving financial services landscape that increasingly relied on internet and mobile banking channels to access insured depository institutions. The Advertising Rule was adopted to “bring the certainty and confidence historically provided by the FDIC official sign found at banks’ teller windows” across all banking channels. The Advertising Rule required FDIC official signage on all banking channels and clearer distinctions regarding insured deposits and noninsured products.
Prior to the adoption of the Advertising Rule, it was 15 years since the FDIC had updated its signage and advertising rules. The FDIC introduced the Advertising Rule in response to the proliferation of digital and online banking, which, according to the FDIC, had grown to be the primary methods of bank account access for nearly two-thirds of all households. The FDIC also acknowledged that a wider array of financial products and services, particularly those offered by non-insured non-bank financial services providers, risked confusing consumers as to the security of their deposits and the applicability of the FDIC’s coverage. This was of a particular concern following the regional banking crisis of 2023 that was exacerbated by fear of uninsured deposits.
The 2025 Amended Signage Rule
The Proposal, published in the Federal Register on August 21, 2025, cites industry concerns that the Advertising Rule is operationally challenging for insured depository institutions to implement and results in greater “consumer confusion.” Stakeholders detailed issues with the technical aspects of complying with signage requirements across diverse digital channels and achieving appropriate disclosures when marketing multiple products.
The Proposal aims to provide greater flexibility, and, according to the FDIC, would allow banks “to tailor digital signage placement to better meet the needs of the customer, resulting in more targeted and less duplicative disclosures.”
Key changes set forth in the Proposal include:
- Flexibility in sign design: Banks will have more freedom with the colors, fonts, and font sizes used for the FDIC sign, provided it is still displayed clearly, continuously, and conspicuously.
- Limited placement of digital signs: The requirement to display the FDIC sign will focus on the initial and log-in pages of digital deposit-taking channels, as well as the page where consumers first interact with their deposit account.
- Streamlined non-deposit signage: Disclosures related to products that are not FDIC-insured (i.e., “not insured by the FDIC,” “not deposits,” and “may lose value”) will be limited to pages and screens that are primarily dedicated to non-deposit products, rather than being required on every page with an incidental reference.
- Third-party notifications: The Proposal modifies how notifications are presented when a consumer moves from a bank’s website to a third-party site via a hyperlink, allowing for automatic dismissal after a short period (no less than three seconds).
- ATM signage: The Proposal offers greater flexibility for ATMs, including the option to use a physical sign instead of digital screens, and requiring the official FDIC sign only on the initial screen of the ATM.
The Proposal is open to public comment until October 20, 2025. If finalized, the Proposal will take effect on January 1, 2027.
