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An announcement of our new Board of Directors member ran in the local newspaper. The announcement consisted mainly of his bio. The only mention of the bank was: 1) in the title: Dr. Mason Joins Altamaha Bank and Trust Board of Directors, 2) in picture caption: Dr. Lloyd Mason & Brent Sammons, Bank President & CEO, and 3) in the last sentence of the announcement: Please help us welcome Dr. Mason to the Altamaha Bank and Trust Board of Directors. I considered this an ad and have noted compliance violations of not having the FDIC and EHL logos. Management considers this an “announcement” not an “advertisement”. What is your opinion? Thanks in advance for your help!
The FDIC regulation states:
12 CFR 328.3(a) Advertisement defined. The term “advertisement,” as used in this part, shall mean a commercial message, in any medium, that is designed to attract public attention or patronage to a product or business.I think generally press releases that are not advertising a product or service of the FI have not been viewed as advertisements. Some banks include them on all information that leaves the bank (press releases and advertisements) which makes the marketing and compliance staff’s jobs easier (i.e. include them on everything that isn’t Non-Deposit Investment Related – separate Not, Not, May disclosures required for those – so they don’t have to decide which items to include them on). This is my preference and recommendation.
You might consider it a “recommended action” to adjust the procedure related to use of logos to ensure consistency and compliance (less room for errors). Just be sure if you bank is releasing information or doing ad on NDIP they follow the NDIP disclosure requirements.
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