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Letter 35: Advertising and Signage, Designation of Banks and Branches

With the increase in the number of multi-bank holding companies and the expansion of the number of eligible branch locations, this office has received a number of inquiries regarding the appropriate designation of a bank or a branch office in advertising and signage. These inquiries reflect a desire to identify banks and branches with the communities they serve. They also reflect a desire to identify each bank and its branches with the holding company with which they are affiliated. Efforts to accomplish these results may include the adoption of a trade name or other designation which is unique to a particular group of institutions. This trade name or designation may differ in some respects from the legal name described in the charter of any particular unit bank.

A bank may, consistent with Wisconsin banking law, adopt a trade name or other unique designation for use in advertising and signage. This trade name or designation may be different from the bank's legal name. It should, however, include the work "bank." A common designation may be used by all banks in a holding company and their respective branches. Similarly, a common designation may be used by a unit bank and its branches. The common designation may or may not be accompanied by words describing the geographic location of the bank or the branch.

Bank management should exercise prudence in adopting a common designation and assure that it is not confusing to the public. A common designation should not be similar in any material respect to the name of any bank with which the bank adopting the common designation is not affiliated. Any bank or bank holding company wishing to reserve a common designation for its exclusive use should review Sec. 132.02, Wis. Stats., and other appropriate statutes, regarding the regulation of trade names.

The scope of this interpretive letter is limited to advertising and signage. A Wisconsin state chartered bank must continue to use the approved legal name in its charter on all official documents including its checks and other negotiable instruments.

Bkg. Ltr. #35, May 10, 1983, Commissioner Dixon