I've been digging through the FDIC Act and the Rules and Regulations for any verbiage that discusses disclosure requirements regarding the FDIC certificate that the FDIC sends you that basically states,

"Federal Deposit Insurance Corporations hereby certifies that the deposits of each depositor in ABC Bank are insured to the maximum amount provided by the Federal Desposit Insurance Act"

The certificate has a nice flashy gold FDIC seal, it provides an FDIC Certificate Number, is dated, attested by an Executive Secretary and signed by the Chairman of the Board of Directors.

I'm trying to find any verbiage that discusses any disclosure requirement regarding this certificate, but I can't seem to find anything that addresses this in the FDIC Act and any Rule or Regulation.

Can any of you sharp bankers out there point me in the right direction?

Thanks in advance!

Disclosure of certificates is not required. This is mentioned in FIL 45-2004 (see last sentence)

Thanks for the response MN Banker.

My only issue with the letter is that it doesn't provide any regulatory reference or general reference to where certificates of deposit are discussed or mentioned anywhere in the Act or the FDIC Rules and Regulations. In other words, where in the Act or the rules and regulation does it address that the FDIC will mail out an original certificate of deposit that will contain a certificate number as well as a statement certifiying that the deposits of each depositor are insured. Where in the Act or Rules does it address that displaying the certificates is optional.

The intent of this FIL is to inform the insured institution that the FDIC will no longer mail out multiple original certificates for display to "other" offices but rather will just mail out one original certificate for display at the "main" office while providing "generic" certificates for display at other offices upon written request. It's nice that the FIL notes/reminds us at the end of the letter that the certificates of insurance are not required by FDIC rules and that displaying the certificates is optional. I guess I was hoping for a reference to a rule or the act that addresses this....but this FIL nonetheless should suffice.

Again, thanks for providing!

We recently opened a new branch and I contacted FDIC for this certificate to display in the branch and they informed me that they no longer provide this to banks. They did, however, send me a copy of our original charter insurance certificate (with no gold seal) that I could display IF I wanted to. Our head of branch administration wanted a certificate of some sort (I think she thinks we look more official with one), so we ended up displaying this "copy". It's pretty plain and basic and doesn't look official, but it came straight from FDIC. Do you have access to the FDIConnect? That's where you can order this copy certificate. Right online.

And on another note - most examiners take FILs as law, so don't disregard them. They'll criticize something and cite a FIL as quick as anything.

It's hard to find things that don't exist. Most regulations tell you want you have to do and not want is not required.

True, but not everything you can't find is something that doesn't exist. Many times what you can't find is there somewhere, maybe even under your nose, but you may be looking in the wrong place.

While most regulations tell you what you have to do opposed to what you don't have to do, at a minimum, most regulations still provide general information or guidance on many specifics related to an act or regulation. In other words, something can be discussed or mentioned in the Act or regulation without having to spell out specific requirements.

With respect to the FDIC certificate of insurance which contains a certificate number, I don't believe it's unreasonable to expect or assume that "certificates of insurance" as well as "certificate numbers" would be discussed in some capacity somewhere in the Act or regulation without having to specifically spell out any disclosure requirements.

Interesting. I called the FDIC on Wednesday and left a message. It's now nearing the end of the work day on Friday and they haven't returned my phone call. I have multiple original certificates available. Again, I wasn't sure what the diclosure requirements were with respect to these certificates. I tried to find any verbiage in the act or rules or regulations regarding this certificate and had a difficult time finding anything. The FIL above that MN Banker kindly provided is the best piece of information provided that clearly states and points out that displaying the certificate is optional. Still, it's my nature to want to see specifically what an Act, rule, regulation, policy, etc. says hence my itch to still want to know where in the Act, rule or reg are "certificates of insurance" and "certificate numbers" are addressed.



Ain't that the truth.

Thanks for your responses by the way and have a good weekend!