I need some help figuring out one component of the recent FDIC Interim Rule. I would appreciate your thoughts on the following.
The notification of the Interim Rule stated "We strongly encourage owners of revocable trust accounts to make certain that the names of their beneficiaries are included in the bank's records."
I just looked at the Federal Register published Interim Rule. I noticed the following was paragraph was no longer there:
"330.10(f)(4) In order for a depositor to qualify for the living trust account coverage provided under this paragraph (f), the title of the account must reflect that the funds] in the account are held pursuant to a formal revocable trust.[b There is no requirement, however, that the deposit accounts records of the depository institution indicate the names of the beneficiaries of the living trust and their ownership interests in the trust."[/b] However, the only reference to requiring beneficiary records was for informal trusts.
Based on the above, is there still no requirement that foraml revocable trusts indicate beneficiary names in the deposit account records? Thanks for your help.
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CRCM