Maryland Legal Alert for Financial Services
FDIC Proposes Further Revisions to Digital Deposit Signage Rule
On August 21, 2025, the Federal Deposit Insurance Corporation (FDIC) proposed revisions to its Official Sign and Advertising Rule, codified at 12 CFR Part 328, which was previously set to take effect earlier this year.
The FDIC’s proposal aims to reduce compliance burdens by eliminating strict formatting and color code requirements for the FDIC sign on digital platforms. It also provides more flexibility in how the ‘clear and conspicuous’ standard is applied to ensure consumer visibility. The proposal also refines where FDIC and non-deposit signage must appear on digital platforms. Specifically, the FDIC digital sign would be required only on login and account-opening screens, rather than on all landing pages. Non-deposit signage, such as for cryptocurrency or investment products, would be limited to pages primarily dedicated to those offerings.
Additionally, the proposal simplifies signage requirements for ATMs and similar devices, limiting display obligations to the initial transaction page or screen for non-deposit transactions. ATMs installed before January 1, 2027, or those not supporting non-deposit transactions, have the option to display either the digital or physical FDIC sign. The proposal further clarifies that non-deposit signage would only apply to ATMs that accept deposits and also offer non-deposit products, and only on screens visible to the institution’s customers.
Finally, the proposal would allow financial institutions to meet the one-time notice requirement for customers accessing non-financial institution third-party platforms through a brief, dismissible notification, either manually closed or automatically after at least three seconds.
Comments on the proposed rule are due by October 20, 2025. The FDIC has proposed a new compliance date of January 1, 2027.
Practical Pointer: Financial institutions and service providers should begin assessing their digital account-opening, login, and non-deposit product screens to identify where signage adjustments may be necessary. It is advisable to review the FDIC’s examples of compliant signage placement that satisfy the “clear, continuous, and conspicuous” display requirement.
For more information, contact Tamia J. Morris.