FDIC signage compliance checked on every website, app, ATM and partner screen, each check cited, each finding closed only on a recapture
Every screen checked against Part 328 monthly; no finding closed without a recapture.
See one case, screen by screen ↓FDIC signage compliance means meeting 12 CFR Part 328: the official sign at teller windows, the FDIC digital sign on the homepage, login page and first account-opening page of every website and app, the sign on the initial screen of deposit-taking ATMs, and no screen — a fintech partner's included — misrepresenting insured status. FDIC Signage Compliance has agents capture every screen at its true size, mark where the sign must be, check it with the passage cited and draft the correction, for a reviewer to check and the Compliance Officer to approve.
AI use cases in banking: a buyer's guide to agentic AI for bank and credit union operations →
Updated
FDIC signage compliance now reaches far past the teller line. Under 12 CFR Part 328 every insured bank shows the official sign at its teller windows, the FDIC digital sign on the homepage, the login page and the first page of deposit account opening of every website and app, and the sign on the initial screen of every deposit-taking ATM, with the digital and ATM rules applying from April 1, 2027. It also answers for its fintech partners: under subpart B, a partner app that says "your money is FDIC insured" without naming the bank or saying what FDIC insurance covers misrepresents insured status.
Today the check is an annual review with a checklist and screenshots taken by hand. The list of pages that take deposits is out of date the week a campaign launches. Partners send the screenshots they choose, at the size they choose, from the build they choose. Nobody compares an ATM's idle loop with its initial screen, branch managers tick an attestation nobody sees, and findings close when someone says "fixed" — then reopen at the exam.
Estimated split of people's hours for one cycle over a community bank's 1,140 screens, by hand at about six minutes a screen and with the solution. Our arithmetic, not a measured result.
Eight agents capture, mark and check every screen and draft the fix; a reviewer checks, the Compliance Officer approves.
Tessaly Community Bank, a $3.4 billion community bank with 41 branches, 58 ATMs and 9 fintech partners, has 161 days left before the digital and ATM sign rules apply. Here is one Thursday morning in the working solution, and the nine days behind it.
Celeste's desk covers 1,140 screens across the bank, its ATMs and branches, and 9 fintech partners. It shows 161 days to April 1, 2027, 182 of 214 places ready, 10 decisions waiting for her — 7 findings and 3 closures — and 3 partner fixes overdue. This morning the agents recaptured Fernway's app and drafted a new correction request; 14 screens they could not reach are listed for a person.
7:17 AM · Rules agent: “Fernway home recapture — 5 of 5 pass.”
The monthly partner recapture captures all 74 screens of the Fernway app, version 5.17, at 390 × 844 with test account FW-TEST-07. The home screen shows a $2,418.36 balance and a banner: “Your money is FDIC insured up to $250,000.” The overlay marks where the FDIC digital sign and the bank's name belong, and the claim that breaks the rule. Three of five checks fail.
Nothing on the screen names Tessaly Community Bank, says Fernway is not a bank, or says what FDIC insurance covers.
Each check names its source — the regulation or the bank's program agreement — and its confidence. A click on § 328.102(b)(5)(ii) opens the passage with rule set R-2026.1, amended by 91 FR 3812 on January 29, 2026: a non-bank speaking about deposit insurance must say it is not an FDIC-insured institution. The Fernway banner says neither.
“FDIC insurance only covers the failure of the FDIC-insured depository institution.”
Henrik Solberg checked the finding, Celeste approved it with its drafted request, and Dashiell Okafor sent it through the partner portal to Fernway's head of compliance, due October 27. Fernway reported version 5.18 on October 21. At 7:15 AM the agent recaptured the home screen at the same size with the same test account: the FDIC digital sign and “Banking services provided by Tessaly Community Bank, Member FDIC” now sit under the Fernway name.
5 of 5 checks pass · Fix verified · closure awaiting.
The October 13 capture and the October 22 recapture sit side by side at the same size, and the same five checks run twice: fail, fail, pass, pass, fail, then pass on all five. Henrik proposed closure at 8:40 AM. Celeste approves it against the two screens — or reopens it with a reason code.
“Request sent Oct 13 · fix reported Oct 21 · recaptured Oct 22 — 9 days, due Oct 27.”
Because the app version changed, every Fernway screen was recaptured. A new Invest screen says “Grow your round-ups — protected like your Fernway balance” beside an FDIC shield, for a brokerage product of a non-bank broker. The agent walked the journey as a signed-in customer: “Start investing” leaves for the broker with no one-time notice. Three of four checks fail, confidence 0.94.
Cited: § 328.102(a)(3)(i) · § 328.5(d)(1) · § 328.5(d)(2).
The Drafting agent wrote the request Fernway will read: remove the shield, add the non-deposit disclosure, and show a one-time notice on “Start investing”, each change with the rule behind it, due November 5 under the 10-business-day timeline for insured-status statements. Henrik checked it at 8:52 AM, Celeste approved it at 9:20 and Dashiell sent it at 9:31.
“Investment products are not FDIC insured, are not deposits or other obligations of Tessaly Community Bank, are not guaranteed by the bank, and may lose value.”
Nine programs, 500 screens recaptured on the second Tuesday, 22 open findings and 3 overdue. Sablewick Wallet's “All your money, FDIC insured” above a crypto balance was due October 14, and the fix reached step 2 on October 21: the partner's executive, with Celeste copied. Marrowby is at step 1.
“If Sablewick misses step 2, step 3 is the cure notice under the program agreement — your decision, not mine.”
Of 58 ATMs, 46 take deposits. 35 run screen build 7.4, with the sign on the initial screen. 11 run build 7.2, which shows it only on the idle loop. Branch photos confirm a physical sign at 8 of those 11, which the rule accepts for ATMs in service on or before April 1, 2027. Three off-site ATMs have neither, and that is one finding.
“On the idle loop — this does not count.”
The audit trail keeps every action by people, agents and partners with who, what, when, why and the evidence. For the FDIC examiner the Evidence agent assembles findings and decisions with reason codes, captures with size, version, test account and hash, the cited passages and rule-set version, partner requests and replies, closure evidence and branch photos, and checks that every citation resolves.
“Ready: 49 open and 23 closed findings · 1,126 captures with hashes · 31 partner requests · 16 settings changes.”
The same screens, seen by the five people who carry them — what their year looked like, and what it looks like now.
Eight agents capture, mark and check every screen and draft the fix; a reviewer checks, the Compliance Officer approves.
Visits every page and screen on schedule and after every reported fix, at the device's own size, logged in with test accounts, and walks sign-up and exit journeys like a customer.
Finds the sign, the bank's name, insurance wording, non-deposit products and exit links on each capture, draws the overlay and measures placement.
Checks each capture against 12 CFR Part 328 subparts A and B and the program agreement, citing the passage behind each check.
Groups failing screens by the template, component or build that causes them, so one fix closes many.
Writes the correction request or internal ticket, every sentence cited, with the due date from the timeline for that rule.
Watches due dates, reminds owners, proposes escalation and schedules a recapture when a fix is reported.
Reads branch attestation photos for the official sign at each teller window and the separation of non-deposit products.
Assembles the examiner pack, internal audit pack and board update from the record, and checks that every citation resolves.
Approves every finding and closure; never one she checked. The agents propose; a named person decides.
Ask in plain words, or say what to prepare. Every answer points to the capture or the passage it rests on.
Why did the Fernway home screen fail, and is it fixed?
On October 13 the home screen said “Your money is FDIC insured up to $250,000” and nothing else. Fernway is not a bank, so it has to say so, name the bank that holds the money, and say that FDIC insurance only covers the failure of the FDIC-insured depository institution. The program agreement also asks for the FDIC digital sign beside the Fernway name. Fernway released 5.18 on October 21; the recapture this morning, at the same size and with the same test account, passes 5 of 5 checks. Henrik proposed closure; it waits for your approval.
Which places are not ready for April 1, 2027?
32 of 214, covered by 30 open findings: 8 on the website (the Apply-start template alone fixes 4 account-opening pages), 10 in online banking and the app, 4 deposit-taking ATMs and 10 on partner apps. What could slip: the three partner fixes already late, the 14 screens the agents cannot reach yet, and the ATM build schedule. At this cycle's closing rate the rest close by mid-January — an estimate, with ten weeks of margin.
Which partners are late, and what happens next?
Sablewick Wallet has two insured-status findings due October 14 — “All your money, FDIC insured” above a Bitcoin balance, and an FDIC shield on its crypto screen. It reached step 2 on October 21: its executive, with you copied. Marrowby is 3 business days late on a pass-through claim with no conditions, at step 1. If Sablewick misses step 2, step 3 is the cure notice under the program agreement — your decision.
Do the 11 ATMs on build 7.2 need a new build before April 2027?
Not all of them. Build 7.2 shows the sign only on the idle loop, which the rule does not count as the initial screen. But a physical sign is accepted on ATMs in service on or before April 1, 2027, and branch photos confirm one at 8 of the 11. The 3 off-site ATMs have neither. Three physical signs close the gap fastest; build 7.4 closes it for good.
13 screens from the working solution, on its sample data. Pick one to see it large.
Schedules, rule versions, thresholds and timelines are settings. A change is versioned and takes effect only when the Compliance Officer approves it.
| Setting | Default | Choose from |
|---|---|---|
| Monthly recapture | Bank channels the third Monday · partners the second Tuesday | Proposed by the administrator, approved by the Compliance Officer |
| Recapture on a reported fix | Within 12 hours · same size, same test account | On · Off |
| Recapture the whole app on a new version | On | On · Off |
| Device sizes | 390 × 844 and 412 × 915 phones · 1280 × 800 web · 800 × 600 ATM | Proposed by the administrator, approved by the Compliance Officer |
| Rule set and program agreement | R-2026.1, 12 CFR Part 328 as amended by 91 FR 3812 · Schedule D v3 | A new version applies once the Compliance Officer approves it |
| Agent confidence threshold | 0.90 for the Layout, Rules and Branch Sign agents | Set per agent, with its prompt version |
| Due dates by rule | Insured-status statements 10 business days · missing sign 20 · placement and advertising 30 · premises 15 | Set per rule |
| Escalation | Reminder 3 days before due · step 1 at due · step 2 at +5 business days · step 3 cure notice, the Compliance Officer decides | Steps and days set by the Compliance Officer |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our arithmetic (about six minutes to check one screen by hand), not a published figure · “typical” = published rules (12 CFR Part 328, subparts A and B; FDIC FIL-5-2025; the final rule amending §§ 328.4 and 328.5, 91 FR 3812, January 29, 2026). Tessaly Community Bank, its fintech partners and the people, screens and finding numbers named on this page are fictional — characters and sample data in the working solution.
FDIC signage compliance means meeting 12 CFR Part 328: the official sign at teller windows, the FDIC digital sign on the homepage, login page and first account-opening page of every website and app, the sign on the initial screen of deposit-taking ATMs, and no screen — a fintech partner's included — misrepresenting insured status. FDIC Signage Compliance has agents capture every screen at its true size, mark where the sign must be, check it with the passage cited and draft the correction, for a reviewer to check and the Compliance Officer to approve.
For the digital sign and ATM rules in §§ 328.4 and 328.5, April 1, 2027, set by the final rule published January 29, 2026 (91 FR 3812). It moved four times to get there: January 1, 2025, then May 1, 2025, March 1, 2026, January 1, 2027 and April 1, 2027. The readiness screen counts the days and shows every place the rules reach, ready or not, by channel.
The FDIC digital sign must be clear, continuous and conspicuous on the homepage, the login page and the first page of deposit account opening, near the bank's name. Pages primarily about non-deposit products carry non-deposit signage, and a signed-in customer leaving for a non-bank's non-deposit product gets a one-time notice per session, dismissed by a click or swipe or shown at least three seconds. The agents walk those journeys with test accounts to see whether the notice appears.
A deposit-taking ATM shows the FDIC digital sign on its initial screen, and an idle screen or screen saver is not the initial screen. A physical sign may substitute on ATMs placed in service on or before April 1, 2027. The agents capture both the idle loop and the initial screen of each ATM build and match branch photos to see which ATMs a physical sign covers.
Yes. The Capture agent logs in to each partner's app and web sign-up flow with a test account and walks it like a customer. Each check cites the regulation passage and, where it applies, the program agreement clause the bank wrote to monitor its partners, labeled so the partner knows which creates the obligation. The agent never uses a customer's login or bypasses a bot check; a screen it cannot reach goes to a person.
No. A reported fix schedules a recapture of the same screen, at the same size, with the same test account, on the new version. Only a passing recapture lets the reviewer propose closure, and only the Compliance Officer approves it, with both captures side by side.
Yes. The agents capture, mark, check and draft; they never approve, send, close or contact a partner. A reviewer checks each finding, the Compliance Officer approves it and never one she checked herself, the program manager sends the request, and settings changes take effect only when the Compliance Officer approves them. Any check can be overridden with a reason code that stays on the record.
The Agentic Solution Engine builds and deploys it from your requirements and documents — your channel inventory, partner program agreements and sign standards — and it goes live once every quality gate has passed. We will walk you through it on a sample of your own screens first.
Every overdraft and NSF fee tested, not a sample, and refunds sized before the exam.
1-min demoCRA ComplianceEvery community development activity qualified from its source document, then signed.
1-min demoConsumer Compliance TestingEvery item tested, not 60, and every exception evidenced before the exam.
1-min demoWe'll run FDIC Signage Compliance on a sample of your own website, app, ATM and partner screens.