The Board of the FDIC met on October 17, 2024, and delayed the implementation date for the updates to 12 CFR 328 Subpart A (FDIC Official Signs and Advertisement of Membership) which were to go into effect on January 1, 2025. The new mandatory compliance date is May 1, 2025.
According to a memo from FDIC Staff to the Board recommending a delay, the FDIC has provided clarifying information through two Bankers’ Webinars and two sets of “Questions and Answers” addressing the most frequently asked questions. However, institutions and other industry participants have continued to raise questions about the application of the rule as well as concerns with updating their software for digital deposit-taking channels and ATMs by the January 1, 2025, compliance date. A delay of the compliance date would also give the FDIC an opportunity to review recently submitted questions and consider providing further clarifications to IDIs about Subpart A through publishing additional “Questions and Answers,” as necessary.
The requirements of Subpart B (False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC’s Name or Logo) remain effective on January 1, 2025.
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 have been updates to the Q&A on August 16, 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.
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