This may be a stupid question, but when the guidance states that we must post the prescribed notice on our Web site, if applicable, what does this mean? If we have a Web site, we must post it?

First of all, it's not a TAG disclosure. TAG dies on 12/31/10. The new program is actual FDIC insurance coverage (not a TAG guarantee) for unlimited amounts, on noninterest-bearing transaction accounts (read: DDAs). The notice prescribed by 12 CFR 330.16(c)(1) goes on your website if your customers can touch their accounts in any way through that site: obtain balance info, make transfers, see transaction history, make transfers, open an account, place stop payments, or anything else.

Thank you.

Question on the website notice - I haven't seen or found this addressed anywhere, but how long do we have to leave the notice on the website? Does it have to remain there until 12/31/2012? Marketing is not very happy with me taking up valuable real estate on the homepage and wants to know how long it has to stay there.

I believe the posting requirement is through 12/31/2012.

Reads Regs is correct. The lobby/website notice must remain through 12/31/2012, the current end of the temporary full insurance coverage for noninterest-bearing transaction accounts. I imagine that, if Congress for some reason extends the coverage beyond that date, the FDIC will require that the notice remain longer, too.

FYI, I tweaked the Topic Name to change "Tag" to "FDIC" to prevent confusion. TAG is dead as of 12/31/10. The temporary coverage is actual FDIC insurance, not a guarantee. Splitting hairs, yes. But the lobby and website disclosures are not about the TAG program.

Thank you for the input.

The FDIC has posted some FAQs on their website about the requirements. http://www.fdic.gov/deposit/deposits/unlimited/index.html Use the menu bar on the left to navigate to the different pages.

Here's one of the Q & As that confirms what was stated above.
"For how long must the Dodd-Frank Notice remain posted?

The Dodd-Frank Notice must be posted by all IDIs through December 31, 2012, when the temporary unlimited deposit insurance for noninterest-bearing transaction accounts expires, as provided by the Dodd-Frank Act."

When the FDIC Q&As state that the new requirement applies to all noninterest-bearing accounts regardless of account owner, this means it applies to consumer and commercial noninterest bearing accounts correct?

What about a commercial analysis account that is charged a full account analysis and then receives an earnings credit calculation to offset the cost of fees. Would that be considered interest?

Yes, it applies to all noninterest-bearing transaction accounts, regardless of ownership or the purpose for which opened. See question 4 in the FDIC's FAQ.

Waiver of fees for a commercial account based on account analysis or for any other reason doesn't make that waiver the payment of interest. See question 9 in the FAQ.

http://www.fdic.gov/deposit/deposits/unlimited/coverage.html

So that Analysis account would be covered by the new insurance limits so long as we do not state that we pay interest.

So long as you state that you do not pay interest and you do not, in fact, allow the analysis credits (AKA waived fees) to exceed the amount of fees for the cycle. Any excess credits would have to be lost or carried over to the next cycle.

Hi there. I read through the FR Notice regarding the required disclosures for unlimited FDIC coverage on non-interest bearing accounts (11/15/10) and did not find any definition for "Internet deposit services." We must post the requireed disclosure on our website if we provide these services. Where did you get the definition for it that states it is touching the account in any way online - transfers, viewing balance info, etc.? Thank you!

Never mind...found the answer in the Financial Reform thread. Thanks!