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#1418922 - 07/22/10 07:55 PM Re: Increased FDIC insurance - now permanent AuditorK
MyScamper Offline
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Between here and there
The TARP GUARANTEE for non-interest bearing accounts expires 12/31/10. It currently includeds NOW and IOLTA accounts. As of 12/31/10 there be unlimited INSURANCE for all non-interest bearing transaction accounts but this will NOT include NOW or IOLTA accounts. Note Guarantee v. Insurance, as FDIC was always stressing TARP was guarantee. So if you currently do NOT particpate in TARP guarantee, you will have to wait until 12/31/10 to have your non-interest bearing transaction accounts covered. Since TARP guarantee itself is not being extended, no need to add or change signage right now for it. This is sec. 343 of Dodd-Frank.

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#1419083 - 07/23/10 03:29 AM Re: Increased FDIC insurance - now permanent MyScamper
John Burnett Offline
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And the unlimited coverage provision in the Dodd-Frank Act has a sunset at the end of 2012.
Last edited by John Burnett; 07/23/10 03:31 AM. Reason: oops
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#1419863 - 07/26/10 05:23 PM Re: Increased FDIC insurance - now permanent John Burnett
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We do not participate in the TAG program and our lobby disclosures currently state that the Bank is not participating in the FDIC's Transaction Account Guarantee Program. Customers of the Bank with non-interest bearing transaction accounts will continue to be insured through December 31, 2013 for up to $250,000 under the FDIC's general deposit insurance rule (this is the required verbiage from the FDIC - Temporary Liquidity Guarantee Program FAQs).

Should I delete the 12/31/13 expiration date in this disclosure and replace with 12/31/10? Then in January update the disclosure again, to show the unlimited coverage for non-interest bearing transaction accounts from 1/1/11 - 12/31/12?

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#1420000 - 07/26/10 09:10 PM Re: Increased FDIC insurance - now permanent BNKO
John Burnett Offline
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That wording does need to be updated. The FDIC is working on amendments to 12 CFR 330. I think you can eliminate the "Customers of the bank with non-interest .... " sentence from your disclosures if you have updated other information to removed any reference to "temporary" or "revert to $100,000."
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#1422051 - 07/30/10 03:32 PM Re: Increased FDIC insurance - now permanent edAudit
Soccer Offline
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FDIC states that the increase is effective 7/22/10, does anyone know if current signage in branches is compliant until new signs can be obtained?
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#1422124 - 07/30/10 04:21 PM Re: Increased FDIC insurance - now permanent Soccer
Doug Hendrickson Offline
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We have new signage on order and are keeping our current signage until then. Since the insurance is at least good through the date on the signage, and it doesn't say that it reverts to any other amount on that date, it is still technically compliant, no?
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#1422190 - 07/30/10 05:33 PM Re: Increased FDIC insurance - now permanent AuditorK
Soccer Offline
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I would think that would be the rule. They have to give us time to obtain the new signage.
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#1422192 - 07/30/10 05:37 PM Re: Increased FDIC insurance - now permanent Doug Hendrickson
dg Offline
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Not sure I am getting the picture here. We do participate in the TAGP and we have the required disclsures posted (Bank ____ is participating in the FDIC's Transaction Account Guarantee Program. Under that program, through
December 31, 2010, all non interest-bearing transaction accounts are fully guaranteed by the FDIC for the entire amount in the account. Coverage under the Transaction Account Guarantee Program is in addition to and separate from the coverage available under the FDIC's general deposit insurance rules.. DO I need to remove or change the signs?

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#1422209 - 07/30/10 06:01 PM Re: Increased FDIC insurance - now permanent Doug Hendrickson
Bob The Banker Offline
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Originally Posted By: Doug Hendrickson
We have new signage on order and are keeping our current signage until then. Since the insurance is at least good through the date on the signage, and it doesn't say that it reverts to any other amount on that date, it is still technically compliant, no?

You do have le-way in the time period it takes to order new signs. However, your sign is not compliant because it states the coverage will expire, thus a customer may refrain from opening a 3 year CD because it would not be covered the final year.
Last edited by Bob The Banker; 07/30/10 06:01 PM.
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#1422253 - 07/30/10 06:34 PM Re: Increased FDIC insurance - now permanent Bob The Banker
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I just spoke to a representative from the FDIC and he stated that the current signage not the (TAGP) would be sufficent for the time being because they are not able to complete all the orders that they are receiving based on the passage of the Dodd, Frank bill. I would hope that branch personal would know to communicate to the customer the change.
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#1422706 - 08/02/10 03:56 PM Re: Increased FDIC insurance - now permanent Soccer
John Burnett Offline
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Keep your TAGP notices in place if you are still participating. The TAGP won't expire until 12/31/10, and the extra non-interest bearing transaction account insurance coverage for banks kicks in on 12/31/10.
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#1423238 - 08/03/10 02:19 PM Re: Increased FDIC insurance - now permanent John Burnett
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Somewhere in the middle
Yes, I have changed my mind on this. Will keep the TAGP notices as is until 12/31/2010, then wait to learn how to address the FDIC insurance extended coverage notice when the time gets closer.
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