The FDIC delayed the implementation date for the updates to 12 CFR 328.4 (Signs for automated teller machines and like devices) and 328.5 (Signs for digital deposit-taking channels) which were originally to go into effect as of January 1, 2025, and postponed to May 1, 2025.
The new mandatory compliance date is March 1, 2026.
According to the press release and Financial Institution Letter (FIL-5-2025), today’s Board action postpones the compliance date for sections 328.4 and 328.5 of the rule to March 1, 2026. The FDIC plans to use the additional time to propose adjustments to the regulation, so we are likely to see additional changes forthcoming.
This delay does not apply to the other amendments made by the final rule to subpart A, such that compliance for those requirements remains unchanged and is required by May 1, 2025. The requirements of Subpart B (False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC’s Name or Logo) remain effective as of January 1, 2025.
While the requirement for policies and procedures under 328.8 were not postponed, a footnote in the Federal Register states the policies and procedures will not need to address the requirements in 12 CFR 328.4 or 12 CFR 328.5, until March 1, 2026, the full compliance date for these provisions.
You can read the update here.
TCA provided an article regarding Questions and Answers (Q&A) on the new signage rule as of July 16, 2024. There were updates to the Q&A on August 16, 2024 and December 9, 2024 and we expect additional updates based on they delayed implementation date and additional inquiries and clarifications from recent webinars.
TCA is your source for information on new and updated regulations. Contact us at [email protected] or (800) 934-7347 for A Better Way to comply.
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