BPI and ABA Comment on Proposal to Modernize Rules Governing FDIC Sign and Advertising Statements

Ladies and Gentlemen:

The Bank Policy Institute[1] and the American Bankers Association[2] appreciate the opportunity to
provide comments on the Federal Deposit Insurance Corporation’s Notice of Proposed Rulemaking Relating to False Advertising, Misrepresentation of Insured Status, and Misuse of The FDIC’s Name or Logo.[3] The proposal is intended to modernize the FDIC’s sign and advertising regulations so that they better reflect the increased use of internet and mobile banking channels to access insured depository institution banking and other services. Additionally, the proposal clarifies the FDIC’s rules regarding misrepresentation of deposit insurance.

To read the full comment letter, please click here, or click on the download button below.

[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group, representing the nation’s leading banks and their customers. Our members include universal banks, regional banks and the major foreign banks doing business in the United States. Collectively, they employ almost two million Americans, make nearly half of the nation’s small business loans, and are an engine for financial innovation and economic growth.

[2] The American Bankers Association is the voice of the nation’s $23.6 trillion banking industry, which is composed of small, regional and large banks that together employ more than 2 million people, safeguard $19.2 trillion in deposits and extend $12.2 trillion in loans.

[3] 87 Fed. Reg. 78017 (Dec. 21, 2022), available at: 2022-27349.pdf (govinfo.gov).