4000 - Advisory Opinions
"Federal Deposit Insurance Corporation" Should Not Be Translated Into Non-English Equivalent on Advertising
August 29, 1995
Valerie J. Best, Counsel
This letter confirms our telephone conversation of August 24th and supplements our letter to you dated August 22nd. A copy of our August 22nd letter is attached for reference.
The non-English equivalent of the FDIC's "official advertising statement" may be used in an advertisement only if the translation has received the prior written approval of the FDIC. 12 C.F.R. 328.3 (e). The "official advertising statement" is the phrase "Member of the Federal Deposit Insurance Corporation" or variations such as "Member FDIC." 12 C.F.R. 328.3 (b). You submitted a Spanish-language newspaper advertisement for auto loans for our review and approval.
The advertisement you submitted contained the following phrase: "Miembro de la Compañia de Seguros de Depósito Federal (FDIC)." FDIC staff found this translation to be accurate and it was therefore approved through our August 22nd letter. Upon further reflection, we believe that the name "Federal Deposit Insurance Corporation" should not be translated into a language other than English.
We have been advised that in Spanish, as in most foreign languages, proper names are not translated, especially those proper names that have universal recognition. The translation "Compañia de Seguros de Depósito Federal" is a literal translation which, translated back into English, is "Federal Company for the Insurance of Deposits." Without the acronym "FDIC," the impact of the FDIC name is lost to most readers.
The FDIC publishes Spanish-language pamphlets describing deposit insurance. We also produce Spanish-language videos discussing deposit insurance. We do not translate our corporate name into its non-English equivalent in either product. While we do not question the accuracy of your translation, we believe that, for the sake of uniformity and to prevent any confusion, the FDIC's corporate name should not be translated into its non-English equivalent. Instead, for advertisements in Spanish, the official advertising statement "Member of the Federal Deposit Insurance Corporation" is translated "Miembro de la Federal Deposit Insurance Corporation." The authorized short title "Member of FDIC" or "Member FDIC" is "Miembro de FDIC" or "Miembro FDIC".
Based upon our telephone conversation of August 24th, it is my understanding that this alternative is acceptable to you. Please call me at (202) 898-3812 if you have any questions. Thank you for your cooperation in this matter.