I am reading up on the FDIC's disclosure requirements for sweep accounts and am a little confused as to whether a service we offer would be considered a sweep account. Would someone enlighten me please?

We allow customers to "tie" an account to their checking account so when a check comes through and there is not enough money in the checking account to cover the check, our system will automatically transfer (in $100 increments) enough money from the donor account to the checking account to cover the check. We allow any type of account to be used as the donor account.

Would these donor accounts be considered sweep accounts?

What do you mean by "any type of account"? Are all the donor accounts either another deposit account, or a HELOC, or overdraft line of credit? Or would it be a type of investment account?

Only deposit, HELOC, ODLOC. No investment accounts.

Those would not be considered a sweep account under the definition, and would not require disclosures.