4000 - Advisory Opinions
Posting FDIC Signs in Embassy Branches
December 1, 1988
Jonathan Taylor, Attorney
We have received your correspondence of November 17, 1988. Your letter asked two questions regarding deposits received in your Embassy branch in ***.
1. Should FDIC signs be posted?
2. If posted, would this confuse and misrepresent to customers the accounts that are not insured?
You indicated that the Embassy branch accepts deposits, some of which are payable in Washington, D.C., and some which are payable in ***. Deposits can be insured only if they are payable in the United States.
FDIC regulations provide that "[e]ach insured bank shall continuously display an official sign . . . at each station or window where insured deposits are usually and normally received in its principal place of business and in all its branches. . . ." 12 C.F.R. § 328.1. Accordingly, if the Embassy branch usually and normally receives insured deposits, your institution must post the official sign in such location.
As you have noted, however, a sign of this kind may cause some bank customers to believe that all of their accounts are insured, even when the accounts are payable only in ***. In order to avoid confusion, you should post some form of sign or notice explaining that only accounts payable in the United States are insured accounts.