Just want to make sure I am thinking correctly...IOLTA accounts are not covered under section 343 and will not,after 12/31/2010, have unlimited FDIC coverage insurance, I get that; however, considering the FDIC general deposit insurance rules, the clients for whom the law firm holds funds can be insured up to the $250,000 limit individually. So as an example if the IOLTA account has $1 million balance and the funds are for multiple clients, as long as the clients themselves do not have other deposited funds with the bank for which their balances would exceed the $250,000 coverage (ownership for each account considered), the IOLTA account is essentially fully insured?
(referring to 12 CFR 330.7)