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#1466536 - 11/10/10 04:25 PM Re: noninterest-bearing demand deposit accounts Notice CubDave
Funky Falcon Offline
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Minnesota
For our eStatement customers, we usually put a short message telling them that there has been a change affecting their account and then add a link directing them to our website where the full disclosure is located.


The more I read this thread, the more I'm confusing myself... do we have to send this notice to ALL deposit account customers (interest bearning & non-interest bearing, checking, savings, etc) or just to the customers who have NOW and IOLTA accounts?

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#1466544 - 11/10/10 04:29 PM Re: noninterest-bearing demand deposit accounts Notice Funky Falcon
Funky Falcon Offline
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Minnesota
Adding to the above post: we put the message on their statement notification email.

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#1466578 - 11/10/10 05:03 PM Re: noninterest-bearing demand deposit accounts Notice Funky Falcon
DD Regs Offline
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DD Regs
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Somewhere in the middle
1. You have to send to IOLTA and NOW accounts (And can use the model language)
2. Need a Lobby and/or Website sign using model language
3. If applicable, notices to DDA if this is a change for them.



That sums it up. You do not need to send to all checking customers, but you may do it as a BP or Opperationaly it may be easier to send to all, depending on your shops capabilities.
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#1466626 - 11/10/10 05:57 PM Re: noninterest-bearing demand deposit accounts Notice MarieR
Georgia Plum
Unregistered

But why would you want to mail to all consumers rather than those just impacted? Our statements aren't separated by account type so we'd have to mail to all consumers or identify and mail only to those impacted.

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#1466631 - 11/10/10 06:00 PM Re: noninterest-bearing demand deposit accounts Notice CubDave
GoGreen Offline
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Posts: 288
PA
I have another question on the FDIC change concerning "official items". I am wondering if we need to give any notification as the FDIC notice when we sell these items or is the FDIC lobby notice all that is required.

We are removing the TAG disclosure on December 31, 2010.

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#1466684 - 11/10/10 07:09 PM Re: noninterest-bearing demand deposit accounts Notice
DD Regs Offline
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Somewhere in the middle
Originally Posted By: Georgia Plum
But why would you want to mail to all consumers rather than those just impacted? Our statements aren't separated by account type so we'd have to mail to all consumers or identify and mail only to those impacted.


If you have a lame dp like Bankway that cannot separate account statements so that only certain items go into certain acct type statements, leaving you with two options, put a notice in all statements or use a separate software system to distinguish the account types and then do a direct mailing.
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#1466802 - 11/10/10 09:11 PM Re: noninterest-bearing demand deposit accounts Notice DD Regs
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The FDIC posted a summary of the notice requirements as well as the text of the notice on the following page. http://www.fdic.gov/deposit/deposits/changes2.html
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#1466961 - 11/11/10 02:45 PM Re: noninterest-bearing demand deposit accounts Notice Reads Regs
Ski Offline
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South Louisiana
Trying to understand this:

Is this notice a replacement for the current notice we have in our lobbies and on website OR an additional notice?
Our current notice is a "not participating" notice.

Thanks in advance for any clarification forthcoming.

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#1466966 - 11/11/10 03:04 PM Re: noninterest-bearing demand deposit accounts Notice Ski
rlcarey Offline
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Galveston, TX
It will replace the current notice after 12/31/10.
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#1467308 - 11/12/10 07:38 PM Re: noninterest-bearing demand deposit accounts Notice CubDave
rachelchri Offline
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If we offer any type of internet banking service do we have to post the notice online? Our Internet banking is just for inhouse transactions, they can't pay bills or transfer money in or out of the bank through internet banking. All they can do is make online transfers from one account to another account as long as both are under the same customer name.
Last edited by rachelchri; 11/12/10 07:41 PM.
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#1467337 - 11/12/10 08:21 PM Re: noninterest-bearing demand deposit accounts Notice rachelchri
rlcarey Offline
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From my understanding is that if you have a transactional internet site (which it sounds like you do) the notice is required.
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#1467595 - 11/15/10 04:10 PM Re: noninterest-bearing demand deposit accounts Notice MarieR
Frank Ernest Offline
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Somewhere on a beach
The final rule says that "if depositors have more than one affected account, one notice is sufficient if it identifies all the applicable accounts." I understand that to say if you send the notice in a statement with 3 accounts of which 2 are affected you must identify the 2 affected accounts. What if you want to send the notice with a statement that has 3 different accounts but only one of the accounts is affected. Do we have to identify the one account although they do not have more than one affected account? How about if we want to send individual notices to customers who have only one affected account and two other accounts. Would the separate notice have to identify which of their accounts the notice is referring to? The rule only refers to having more than one affected account, it does not say anything about having more than one account, but only one is affected.

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#1468315 - 11/16/10 05:03 PM Re: noninterest-bearing demand deposit accounts Notice Frank Ernest
Kaos Offline
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I must have missed something. If Money Markets are included in the model notice language as not covered, why are we only required to send notices to NOW and IOLTA accounts?

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#1468334 - 11/16/10 05:20 PM Re: noninterest-bearing demand deposit accounts Notice Kaos
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Illinois
Because Momey Markets weren't covered under TAGP.
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#1468507 - 11/16/10 08:24 PM Re: noninterest-bearing demand deposit accounts Notice MyBrainHurts
John Burnett Offline
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The purpose of the mailed notice is to call special attention to the change to the eyes of the accountholders who are currently fully covered under the TAG program and will not be fully covered under the DFA section 343 temporary insurance.
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#1469541 - 11/17/10 10:21 PM Re: noninterest-bearing demand deposit accounts Notice John Burnett
zitch70 Offline
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Edinburg, Texas
Will the model notice suffice in complying with #2 of the notice requirements?

2. IDIs currently participating in the Transaction Account Guarantee Program ("TAGP") must notify Negotiable Order of Withdrawal ("NOW") account depositors and Interest on Lawyers Trust Accounts ("IOLTA") depositors (currently protected under the TAGP) that, beginning January 1, 2011, those accounts no longer will be eligible for unlimited protection;

That notice even if mailed only to NOWs and IOLTAs does not state THIS account will only be covered for $250M, or your account #### will only be covered for $250M. So the customer may still not understand which of their 3 accounts has what coverage.

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#1469597 - 11/18/10 01:30 AM Re: noninterest-bearing demand deposit accounts No zitch70
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Although the FDIC says in the Federal Register document that you can use the lobby notice language for your notice to current TAG-protected accounts, I see your point. You could add to the notice language to make it clearer, if you think it's needed.
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#1470160 - 11/18/10 09:10 PM Re: noninterest-bearing demand deposit accounts No John Burnett
dusk Offline
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Can you tell me if you feel that if we use the model notice as a statement message on the statement is ok or not? We would like to do this verses a statement stuffer.

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#1470309 - 11/19/10 04:44 AM Re: noninterest-bearing demand deposit accounts No dusk
John Burnett Offline
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If you have the ability to put all that verbiage in a statement message, sure. The requirement is that you mail the notice. There's no requirement that it be on a separate sheet of paper.
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#1470393 - 11/19/10 02:38 PM Re: noninterest-bearing demand deposit accounts No John Burnett
ahkcompliance Offline
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Midwest
We do not participate in the TAGP. The only thing we are required to do is post a notice in our lobby and website. Currently, NOW and IOTLAs are limited to $250,000. If we decide to pay interest on business checking accounts, then we would need to send a notice??

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#1470474 - 11/19/10 03:34 PM Re: noninterest-bearing demand deposit accounts No ahkcompliance
lucyc Offline
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You're correct if you decide in July next year to pay interest on business checking accounts then you will need to provide the notice to the customers that their coverage has changed.
Last edited by lvc; 11/19/10 06:34 PM.
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#1470598 - 11/19/10 05:36 PM Re: noninterest-bearing demand deposit accounts Notice CubDave
traveler Offline
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So - to make sure I understand all of this.
We can send the required customer notice as part of the account statement and it can be a shorter version of the "notice" that we are posting in our lobby?????

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#1470601 - 11/19/10 05:39 PM Re: noninterest-bearing demand deposit accounts Notice traveler
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Yes. If you use the lobby notice wording, you'll know your mailed notice is sufficient from FDIC's perspective. If you have to alter it for space or character count, be careful to ensure the key info is included.
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#1470785 - 11/19/10 08:05 PM Re: noninterest-bearing demand deposit accounts Notice John Burnett
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The following is from the FDIC's site and I just want to make sure this is the language for the new notice to be posted in the lobby, on our website and the language that needs to be given to NOW & IOLTA Customers?


NOTICE OF CHANGES IN TEMPORARY FDIC INSURANCE
COVERAGE FOR TRANSACTION ACCOUNTS

All funds in a “noninterest-bearing transaction account” are insured in full by the Federal Deposit Insurance Corporation from December 31, 2010, through December 31, 2012. This temporary unlimited coverage is in addition to, and separate from, the coverage of at least $250,000 available to depositors under the FDIC’s general deposit insurance rules.

The term “noninterest-bearing transaction account” includes a traditional checking account or demand deposit account on which the insured depository institution pays no interest. It does not include other accounts, such as traditional checking or demand deposit accounts that may earn interest, NOW accounts, money-market deposit accounts, and Interest on Lawyers Trust Accounts ("IOLTAs").

For more information about temporary FDIC insurance coverage of transaction accounts, visit www.fdic.gov.

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#1470796 - 11/19/10 08:22 PM Re: noninterest-bearing demand deposit accounts Notice Snowgirl
John Burnett Offline
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You could have found the same wording in the BOL ABC Soup copy of the regulation (12 CFR Part 330), in section 330.16.

ABC Soup can be found at http://www.bankersonline.com/abcsoup/abcsoup.html

Yes, that's the wording for the lobby notice and your website. You can also use it for the notice you may have to send to IOLTA and NOW account customers under §330.16(c)(2).
Last edited by John Burnett; 11/19/10 08:23 PM.
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