Use of the FDIC Name and Logo: Proceed With Caution
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We discuss the FDIC’s final rule on misuse of the FDIC name or logo, advisory to insured banks on deposit insurance and dealings with crypto companies, and cease and desist letters to five crypto companies alleging they made false and misleading statements about deposit insurance. We also discuss the CFPB’s circular warning that a misrepresentation involving the FDIC name or logo can constitute a UDAAP violation. We then identify key takeaways for banks and non-banks, including action items that should be considered for relationships involving pass-through insurance and the extent to which the FDIC name or logo can be used in advertising of credit products.
Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation joined by Ron Vaske, a partner in the firm’s Consumer Financial Services Group, and Mindy Harris, Of Counsel in the Group.
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