VIDEO: Wrapping the FDIC Digital Sign on Mobile
In this Compliance Clip (video), Adam discusses the essential guidelines for displaying the FDIC digital sign on mobile applications. He explores the challenges faced by financial institutions in ensuring clear and compliant visibility of the FDIC sign on devices with varying screen resolutions.
Video Transcript
The following is a transcript of this video.
This Compliance Clip is going to talk about wrapping the FDIC digital sign on mobile applications. This is a topic that applies to banks that are regulated and have FDIC insurance. So this will not apply to credit unions and institutions that don't have FDIC insurance.
The question we have is this: what should a financial institution do with the digital sign on mobile devices with screen resolutions that do not support the ability to display the full sign or make the sign very small and illegible?
What we have is a new rule that relates to the FDIC's digital sign - a new digital sign rule that has required compliance as of 2025. Now, this digital sign is a big disclosure that doesn't quite fit in mobile applications. It would make it too small.
So our answer, of course, is going to come from the FDIC's Frequently Asked Questions. Frequently Asked Questions No. 6, says this, “Generally the FDIC official digital sign should be displayed as presented with no alteration to the text, except for color variations as noted in the regulation text.” Now, they gave example of the digital sign. As you can see, this is a very long disclosure. And if you try to squeeze this down to fit on a mobile device, that font size would probably be size three, maybe four, maybe even two. It's going to be very small and very difficult to read. So the real question is what do we do for the digital sign on mobile applications?
Fortunately, FAQ No. 6 goes on to say this. It says, “However, if the image does not fit a particular device or screen, the official digital sign can be scaled, wrapped or stacked to fit the relevant screen and may satisfy the clear and conspicuous requirement.” So they give us an example of what wrapped text would look like. And it would be potentially here if this was the top of a phone. So you can, in fact, wrap that text to make it fit on the screen so that you can read it.
So this was something when the rules first came out, I was really curious how they were going to address this because they were adamant that the digital sign had to stay the same. I think they finally realized that that doesn't fit on a mobile device and so they have said that we can wrap text of the digital sign on a mobile device so that it can be legible. So that is permitted and that's how you would address it on a mobile device, because if you don't wrap it, it's not going to be clear and conspicuous. It's going to be difficult to read, and that could be a violation of the FDIC's rules.
So again, this topic applies to banks, but we do have a bunch of topics available and free Compliance Clips, just like this Compliance Clip video in our website at compliancecohort.com