To print this article, all you need is to be registered or login on Mondaq.com. The disclosure requirements for offerings of securities by state non-member banks have long been governed by the Federal Deposit Insurance Corporation's ("FDIC") 1996 Statement of Policy on the Use of Offering Circulars in Connection with Public Distribution of Bank Securities (the "1996 Statement"). 1 The 1996 Statement focuses on disclosure, requires that specific legends be included in offering circulars used by state non-member banks issuing securities and has no filing requirement. The 1996 Statement also refers to the disclosure requirements of the former Office of Thrift Supervision. On January 19, 2021, the FDIC proposed, among other items,