As banks increasingly integrate digital signage into their lobbies, to ensure compliance bankers must apply the FDIC’s updated rules on official signage as carefully as they do for ATMs and websites.

Why worry about digital signage? It all boils down to avoiding penalties. The FDIC is particularly concerned about potential consumer confusion between insured and non-insured products. Misrepresenting deposit insurance, whether through signage, digital displays, or advertising, is strictly prohibited. Failure to comply with the FDIC signage requirements could result in significant penalties.

3 Steps to Apply FDIC Regulations to Digital Signage in Bank Lobbies

1. Review and Choose How to Treat Your Signs

Determine if it makes more sense to A) physically separate your digital signage into deposit and non-deposit zones inside your branch, or B) treat each sign like a website by digitally separating deposit from non-deposit and ads with clear disclosures as your playlist rotates on screen. The method you choose with your compliance team will depend on whether your institution sells insurance and investments, how many screens you have, and in which areas they reside. While it is clear the FDIC is keen on the physical separation of messages in the branch, not all branch designs have teller lines or designated areas for deposit vs. non-deposit transactions. So, with a blended lobby use or a solo digital sign in a general use area, digital signs with bigger, bolder placement of FDIC disclosures could also be considered a compliant display method.

A) Physically Separate Deposit from Non-Deposit: For example, screens behind teller lines or areas where deposit transactions occur would only show FDIC-insured deposit products such as checking accounts, savings accounts, CDs, and money market deposit accounts. In contrast, screens in separate waiting areas or areas where non-deposit products like insurance and investments are managed, show non-deposit media. Problem Solving: Don’t have two digital signs in your lobbies? Ask your service provider if your digital signage player already supports two media channels. If yes, you can likely add another TV without an additional monthly cost. Don’t have time or budget for new screens? Then, it’s best to match the content of your digital sign to the purpose of the area in which it resides – deposit content in deposit areas or non-deposit content in areas away from deposit activity. That way, you are compliant before January 1 and can evaluate the return on investment to add non-deposit digital signs to your 2025 budget. The cost should be easy to justify, as digital signs are cheaper than frequently reprinting paper posters to keep up with disclosures and offer dates.

B) Treat Digital Signs Like Websites: Digital signs are in many ways like a website that shows you one page at a time – over time. So there is a logical path to managing your digital signage FDIC disclosures in the same way you have already updated your website. Problem Solving: Can you simply keep using the disclosures you already have on your digital signs? Not likely. Your effort to disclose will need to be crystal clear and conspicuous to make the bar. Download this sample guide to New FDIC Signage Rules to help you build disclosure messages for your screens.

2. Update Media to Adhere to FDIC Updated Rules

Display FDIC Disclosures Clearly, Continuously, and Conspicuously. Based on the updated FDIC rules and examples for websites and other digital media, and the guidance of your compliance team, consider these updates for digital signage.

FDIC Official Sign: Your logo, used alone or with branding statements, should be treated like your homepage on your website. Your logo should appear with the updated FDIC Official Sign “FDIC-Insured – Backed by the full faith and credit of the U.S. Government” in close proximity, clearly and conspicuously. If using animations, the logo and disclosure should appear simultaneously with any branding logos, text or photos. What if I run a branding commercial that does not currently display this disclosure? In this case, you can add it to your video file or talk to your digital sign service provider about adding an overlay or separate frame with the FDIC Official Sign to ensure compliance.

Non-Deposit Disclosures: Non-deposit product media, such as investment and insurance media, need to have the full text “Non-deposit products: Are not FDIC insured; Are not deposits. May lose value.” This should either be placed under the title of the product, or if your compliance team allows, in the top right corner of the screen. The text should be no smaller than half the font size of your largest text headline to keep it readable.

FDIC Official Advertising Statement: Ads are defined by the FDIC as “a commercial message, in any medium, that is designed to attract public attention or patronage to a product or business.” For example, an ad for a bank-run dog contest that has no clear deposit or non-deposit promotion, is still an ad. The FDIC now allows using “FDIC-Insured” or continuing with “Member FDIC” for digital signage disclosures. What about community events on screen? Your compliance team is best at answering these questions, but if your bank sponsors them, it likely fits the FDIC definition of an ad.

Social Media Disclosures on Digital Signage: Banks displaying social media content on digital signage in lobbies should ensure it follows the same disclosure rules for branding, products, and ads. For best practices, include official signs or logos in the graphics instead of text at the end of your post, as character limits might prevent your disclosure from displaying.

External Content Notices: Some banks include public service media like weather, sports scores, or news that aren’t sponsored by the bank. While the FDIC won’t require an FDIC disclosure, your compliance team or examiners might ask for a third-party media notice, similar to a website departure notice. If there are concerns about displaying these messages, consider adding the following notice to your playlist (display once per media rotation) for clarity. “Notice: This bank does not own or control the media content provided by third parties, such as weather, sports scores, or news. We are not responsible for how you use this content and do not endorse or monitor it.”

Need a copy of the new FDIC official digital sign? You can download the new FDIC digital sign through the FDIC Connect Store at https://www.fdicconnect.gov/index.asp. Or, insured depository institutions can email ocomgraphics@fdic.gov requesting a copy of the FDIC Official Digital Sign. In the request, insured depository institutions should include their bank letterhead as well as the bank’s full address.

3. Build Continuous Education Around FDIC Signage Requirements

Working closely with your compliance team and digital signage vendor is the key to being compliant in time for the January 1, 2025 deadline. However, the real test of success happens in the months following when these new standards need to be reapplied with your marketing updates. If you have not already, schedule monthly monitoring and quarterly reviews with ad agencies and digital signage providers to ensure your media stays on track. This will put you in great shape for your annual full compliance audit and ensure long-term adherence to FDIC regulations and proactive updates for any future changes.

Conclusion

By implementing these steps, your bank can meet FDIC digital signage requirements, ensuring clarity for customers and avoiding potential penalties. Early action and continuous diligence will secure compliance and uphold your institution’s reputation.

If you’re ready for a full-service digital signage solution, schedule a no-obligation discovery call with Director, Content Strategy Sharon Klocek-Ibbotson.