One of the key aspects of the FDIC's new rule is the focus on misrepresentations and material omissions. The rule clarifies specific circumstances under which the use of the official advertising statement, FDIC-associated terms, or FDIC-associated images by a non-bank would constitute a misrepresentation of insured status. For instance, a non-bank's use of the "Member FDIC" logo on its website or in its marketing materials would be a misrepresentation unless that logo is next to the name of one or more IDIs. The rule also addresses situations where non-banks make statements regarding deposit insurance for their customers. It is deemed a material omission for the non-bank to fail to clearly and conspicuously disclose that it is not itself an FDIC-insured institution and that the FDIC's deposit insurance coverage only protects against the failure of an FDIC-insured depository institution.