Author: Andrew Howard
On March 3, 2025, the FDIC announced the postponement of the compliance date for 12 CFR 328.4 and 328.5 rules that were set to go into effect on May 1st of this year. These requirements related to the display of the FDIC official sign on insured depository institution’s digital channels, as well as the requirement related to the institution’s ATMs and like devices. This postponement goes into effect as certain requirements for the digital pages continue to generate questions about the implementation and may result in customer confusing. With this in mind, the FDIC has decided to delay the implementation of these parts to develop proposed changes to the regulation to address the implementation problem and possible sources of confusion.
This delay does not apply to the other requirements stated under subpart A, which still have a required compliance date of May 1, 2025. Sections of Part 328, with changes still effective May 1, 2025, are noted below:
A foot note to the recent Federal Register update states that written policies and procedures need not address section 328.4 and 328.5 changes until the full compliance date for these sections which is noted as March 1, 2026. So, it appears that March 1, 2026, will be the effective date for these sections (328.4 and 328.5) once updates occur. Do note that your financial institution will need written policy and procedures to generally comply with Part 328 by May 1, 2025. We will keep you posted on any updates as they evolve.
FIL-5-2025
FIL-65-2023
12 CFR 328
On March 3, 2025, the FDIC announced the postponement of the compliance date for 12 CFR 328.4 and 328.5 rules that were set to go into effect on May 1st of this year. These requirements related to the display of the FDIC official sign on insured depository institution’s digital channels, as well as the requirement related to the institution’s ATMs and like devices. This postponement goes into effect as certain requirements for the digital pages continue to generate questions about the implementation and may result in customer confusing. With this in mind, the FDIC has decided to delay the implementation of these parts to develop proposed changes to the regulation to address the implementation problem and possible sources of confusion.
This delay does not apply to the other requirements stated under subpart A, which still have a required compliance date of May 1, 2025. Sections of Part 328, with changes still effective May 1, 2025, are noted below:
- 328.3 - Signs within institution premises and offering of non-deposit products within institution premises.
- 328.6 - Official advertising statement requirements
- 328.8 - Policies and procedures
A foot note to the recent Federal Register update states that written policies and procedures need not address section 328.4 and 328.5 changes until the full compliance date for these sections which is noted as March 1, 2026. So, it appears that March 1, 2026, will be the effective date for these sections (328.4 and 328.5) once updates occur. Do note that your financial institution will need written policy and procedures to generally comply with Part 328 by May 1, 2025. We will keep you posted on any updates as they evolve.
FIL-5-2025
FIL-65-2023
12 CFR 328
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