There is a single sentence at the end of the first paragraph HERE that shows the FDIC knows the bill has been signed. But they can't just flip a switch and get all the needed information out on such short notice. Like your bank, the FDIC may have staffers out on holiday vacation, and anything official needs to be vetted by the right level.

Patience, everyone.

We only have a few IOLTAs. We do not currently participate, are we required to notify IOLTAs?

How hard is it to do this?

Again the FDIC has not changed the rules yet, so I would not be making changes without direction from them.

Also, your revision fails to include IOLTAs within your definition of a noninterest-bearing transaction account, and thus still potentially leaving confusion to your customers if you are or are not covering them.

Unless your institution does not offer IOLTAs, then I would opine that your 'revised' disclosure will not pass muster even when the FDIC issues their rule change.

It was joke, I am not serious.

My point is that, the FDIC in anticipation of the rule change, should have been working on the new language. Then when the pres signed they could have immediately released the new language.

In the scheme of things, we may be making a lot more of this than necessary. Consider that regardless of whether you get the notices right, TAGP ends today and the DFA full coverage for noninterest-bearing transaction accounts and IOLTAs starts today. There is literally nothing you can do to foul that up. If you miss a technical requirement like taking down your TAGP notices a day early or a day late, no one is going to run your fingers into the pencil sharpener.

Let's cut the FDIC a little slack here. Congress threw them a curve by even considering the IOLTA thing and did them no favors by waiting until the last minute to pass it. [BTW, has anyone actually taken that bill and looked at it carefully? It looks like it was thrown together without any real forethought, and the amendment makes a mess out of the new section of the FDI Act that was carefully inserted by the DFA.]

Let's sit back, chill out, hoist one of your favorite adult or non-alcoholic beverages to toast the New Year, and wait to see how this all shakes out. And while we're at it, let's hope that 2011 doesn't bring more of the same cr_p raining down on us that 2010 brought!

I'll raise a glass (or two) to that!

Right, just as they were on the ball with releasing the RBP and model privacy notices...

<--------Agrees!!!

I may be a little slow today, but are IOLTAs now fully covered even if they pay interest? Or must they be a non-interest bearing IOLTA?

IOLTAs are covered. And we are patiently awaiting some wording to post. They all earn interest but they don't pay it to the atty.

All IOLTAs are covered.

I thought a non-interest bearing Interest on Lawyers Trust Account would be an oxymoron but I have not seen exactly how congress worded the revision so I was curious.

So do I understand correctly that the interest rate paid on the IOLTAs is no longer a factor?

The interest rate on IOLTAs was never a factor under the TAGP program. NOW accounts were limited to paying no more than .25% under the most recent extension of the TAGP that just expired on 12/31/10.

Under the new Dodd Frank provision as amended by HR 6398, IOLTAs are covered regardless of the rate paid.

Thank you, RR!

I feel like I'm going to miss the communication about the new wording. Has anyone heard anything??????

We actually did stuffers and posted the notices on the website and lobby to comply by December 31 and now we will have to do that all over again.

Nothing yet.

We here at BOL have our eyes peeled for anything from the FDIC. The length of this thread is evidence you are all hungry for the information. We will spread the word as soon as we get it.

Now start worrying about more weighty issues, like the 1/30/11 MDIA changes to Reg Z.

There's always something!

John, regarding MDIA - Reg Z, didn't those get pushed back to 10-1-11? Or am I missing something else?

Does BOL have a good summary?

This is not from BOL (although another BOL poster referenced it in another post), but it's a good summary of the 1/30 Reg Z changes.

Thanks, Deena

The FDIC Board voted at 3:32 ET this afternoon to approve the Summary Agenda for its board meeting, which included a proposed amendment to the FDIC's deposit insurance regulations to accommodate the congressional action to include IOLTAs under the §343 DFA two-year full insurance coverage provision.

I assume that we will see something from the FDIC in the way of an announcement and probably a link to its Federal Register submission document, which I believe will be an interim final rule amending the provisions of §330.16 and the notice requirement language there. Watch BOL's Top Stories and Daily Compliance Briefing for details.

thank you John!