The Bank Policy Institute (BPI) has issued a series of recommendations to the Federal Deposit Insurance Corporation (FDIC) regarding its efforts to clarify FDIC-insured bank products.
The BPI recently joined the American Bankers Association (ABA) in forwarding a comment letter to FDIC Assistant Executive Secretary James P. Sheesley regarding the matter – addressing an FDIC proposal to modernize the rules governing the use of the official FDIC sign and insured depository institutions’ advertising statements.
“We are concerned, however, that the proposal is overly prescriptive and does not sufficiently accommodate current practices and could require significant changes to banks’ digital platforms and physical branch locations,” the BPI and ABA wrote. “Such changes would likely confuse consumers and create unnecessary burden for banks. We urge the FDIC to allow banks greater flexibility to comply with signage and disclosure requirements, accommodate current practices that align with the way technology and the business of banking have evolved and, by extension, the way consumers want to access their funds and other financial services and products.”
The BPI and ABA also maintain that the rules should allow banks flexibility to modify signage, advertising, and other disclosures as appropriate to provide consumers with greater clarity regarding deposit and non-deposit products as technological advancements in banking and financial services continue apace.
Recommendations, according to the BPI and ABA, include the FDIC providing insured banks with the flexibility to implement signage requirements to reflect modern branch design and possible future evolution; the FDIC providing Insured Depository Institutions (IDIs) with the flexibility to implement digital signage requirements to reflect how consumers interact digitally with their IDIs and to account for future evolution; and the proposed rule being revised to accord with the well-established distinction between branches and non-branches.