For those who are posting this on their websites how are you posting it?

Just listing it on your disclosure page?

A link from your home page like "Important FDIC insurance inforation:, then the link takes you to a page showing the FDIC notice?

Just curious how others are placing on their sites.

Big Ol' Banner accross the front page for us.

Does anyone see any problem with sending the notice to all checking account customers even if their account is currently covered and will continue to be covered? The customers with accounts that will be covered until 2013 will receive the same notice that customers with accounts that will not be covered will receive.

If we send the same notice we post in the lobby and on the website, does the notice need to be sent on our bank's letterhead? And do we need to send any kind of explanation for the notice?

We are going to post the notice on our home page with a link "Important FDIC Insurance Information."

We will have a link to the notice on the front page. The link is an icon of the FDIC sign

Input on this? We want to use a notice on our statement but we do not have the capability to separate our account types so we have to either send to all or manually do separate mailing.

Same issue, we are sending to all.

Ditto.

We are sending to all.

We have limited character space on our statements so the entire disclosure will not fit. Is there a condensed version available?

There's no condensed version that's been blessed by the FDIC. You know that the lobby notice language is acceptable. Any departure from that language should be checked carefully to ensure it gets across the same essential message.

You might consider revisiting that decision. The FDIC set up a pretty good "one click away" standard in its FAQ on the almost-outa-steam TGLP. The pertinent Q&A reads:

For institutions that offer internet banking services, does the entire transaction account guarantee program disclosure have to appear on a bank's homepage (or other website that accesses online banking services), or can the institution simply add a link on the homepage that takes accountholders to an appropriate disclosure?

Internet deposit services are defined broadly to include not only deposit taking, but any activity related to a deposit account, such as the ability to pay bills, transfer funds, view account balances, or obtain any account specific information. "Internet deposit services," "online banking services," and "internet banking services" are used interchangeably in these questions and answers. Consistent with the requirements of the Final Rule, the bank's homepage and/or other access point to online banking services must contain the disclosure that the bank is (is not) participating in the transaction account guarantee program. Following such disclosure of participation, an appropriately titled link to additional disclosures would be acceptable. A link titled simply "transaction account guarantee program" does not ensure that accountholders will see the required disclosure. A link titled "FDIC insurance" is even more deficient in that the FDIC transaction account guarantee program does not involve FDIC insurance. Something like "Important disclosures regarding the guarantee program" would seem to be appropriate.

My point is that you might consider substituting text for the FDIC logo: "Click here for important information about FDIC insurance coverage for noninterest-bearing checking accounts."

I missed something small/big.

We haven't participated in the TAG program, so I'm comfortable knowing I don't have to mail anything to anyone other than Santa in December.

I know I have to have a new notice as of 1-1-11.

I missed the commercial checking interest. I found it with Google, but I still need a little help. Is 204.130 being repealed? Or will the law simply be more confusing and now still prohibit NOW account ownership from x, y, and z - but allow DDAs to earn interest? Sorry to take this OT.

The law repealing the sections of the U.S. Code that prohibit the payment of interest doesn't do anything directly to NOW accounts. But it will eliminate the NOW account's raison d'être, and they could fade away. Banks will be able to pay interest on demand deposits on and after 7/21/11, without regard to ownership restrictions. What will go away is Regulation Q.

Thanks John.

when we update our website with the new notice, do we remove the old TAG notice?

FYI...

"Big victory for Florida bankers tonight, by a voice vote, the U.S. House of Representatives passed H.R. 6398 - To require the Federal Deposit Insurance Corporation to fully insure Interest on Lawyers Trust Accounts (Rep. Doggett - Financial Services). We still need the Senate to act on this bill, but passage by the House was a big step in a positive direction.

The FBA has been working the phone lines, has been in Washington several times pushing this bill with U.S. Senators friends of the FBA and with our House delegation as well. Tonight we have been in contact with our House delegation advocating passage of this bill. I want to thank our House members for their support. I also want to thank the American and Florida Bar Associations and our trade groups in DC, it has been pleasure working with them on this, but of course we are not done.

Thanks for supporting the FBA, without you, we would be a paper tigers. Our support has been tremendous this year from bankers who view the FBA as an investment not an expense, even though we are in these challenging times. We will update you again soon on this issue."

The ICBA just communicated that the House has approved a Bill to include IOLTAs in the unlimited insurance coverage. Should we continue with our notification of IOLTAs? We were going to use a statement message notifying NOW and IOLTAs that they would no longer be eligible for unlimited protection as of 12/31/10.

House Approves Bill to Include IOLTAs in FDIC Guarantee
The House passed ICBA-advocated legislation to add Interest on Lawyer’s Trust Accounts to the extension of the Transaction Account Guarantee Program, though the Senate still needs to act before the current TAG Program expires on Dec. 31. With the Senate focused on addressing high-priority budget and expiring tax measures in the short lame-duck session, it is unclear whether the chamber will act on the IOLTA issue. ICBA will continue working with Congress on the issue and will keep community bankers informed of the latest developments.

I guess my thoughts are that we keep going with the statement stuffer/statement message and if need be, notify IOLTAs that they are still covered if need be. What are others planning on doing?

We are doing a smt stuffer for the month of Dec - too late for us...we have already started.

I'm also doing the statement stuffer this month to all deposit accounts since we can't isolate the NOW/IOLTA for statement stuffer/message purposes.

My bank is considering underlining the sentence in the model notice "This temporary unlimited coverage is in addition to, and seperate from the coverage of at least $250,000..."

Would we still have 'safe harbor' if we altered the notice in that way?

You cannot assume that the Senate is going to go along with it. With pass-through coverage, most IOLTA balances, I imagine, are fully covered even under the $250,000 limit. Don't change course in your plans. You can always go back and notify the IOLTA customers if Congress does pass the amendment.

FYI,

Financial Institution Letter
Deposit Insurance Coverage for
Noninterest-Bearing Transaction Accounts
Free Nationwide Seminars for Bank Officers and Employees FIL-83-2010
December 6, 2010

Summary: The FDIC will host two identical telephone seminars for bank officers and employees that will explain the insurance coverage rules and disclosure requirements regarding the new temporary unlimited insurance coverage for noninterest-bearing transaction accounts at all FDIC-insured depository institutions. Each seminar will consist of a 30-minute audio and slide presentation, followed by a one-hour question-and-answer period. The seminars, which are free to officers and employees of FDIC-insured banks and savings associations, will be conducted on December 14 and December 16, 2010.

Distribution:
FDIC-Insured Institutions
Complete Financial Institution Letter: http://www.fdic.gov/news/news/financial/2010/fil10083.html

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