Skip to content
BOL Conferences

Thread Options
#1619702 - 10/25/11 05:22 PM Repeal of Reg Q
Marqann1 Offline
New Poster
Joined: Feb 2011
Posts: 14
Did the repeal of Reg Q - prohibiting corporations from earning interest on a demand account -- ALSO eliminate the references in Reg D & Q to paying premiums on deposits?

Return to Top
Operations Compliance
#1619840 - 10/25/11 07:25 PM Re: Repeal of Reg Q Marqann1
Bob The Banker Offline
Platinum Poster
Bob The Banker
Joined: May 2010
Posts: 958
Originally Posted By: Marqann1
Did the repeal of Reg Q - prohibiting corporations from earning interest on a demand account -- ALSO eliminate the references in Reg D & Q to paying premiums on deposits?

No. Although Reg Q was repealed, the definition of interest was transferred to the FDIC Deposit Insurance Coverage Rule 330. Additionally, the section on premiums was also transferred to the same rule.

Return to Top
#1619946 - 10/25/11 09:06 PM Re: Repeal of Reg Q Bob The Banker
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Q is gone. The only real purpose for the definitions of interest and for the premium rules, which now only exist in the FDIC's regulation for deposit insurance, is to create a bright line definition for payment of interest on transaction accounts.

So, if you tell your customer that his non-interest bearing DDA will be protected until 12/31/12 by the FDIC's unlimited deposit insurance provision in 12 CFR §330.16, but you enticed the customer to open the account with a $250 "gift" for the opening deposit, the gift will be considered interest under the regulation, and the account won't be fully covered under §330.16.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1663085 - 02/09/12 10:54 PM Re: Repeal of Reg Q Marqann1
RGS Offline
Platinum Poster
RGS
Joined: Jul 2002
Posts: 689
Home of the 8 time NCAA Champ ...
Bump.

It's been a long, brutal day so I'd like to throw a bit of a new scenario into this.

Company A serves the public good. They have a sister agency that is a 501(c)(3). In the process of bidding on the business, we are considering making a pledge of a donation to the sister agency if we get the account.

I think that would be a bonus and reportable as interest (though to the non-profit, it's not a big deal). But, since it's interest, Company A would not be eligible to have unlimited deposit insurance. Am I right in this scenario?

TIA
_________________________
Kentucky basketball isn't a matter of life and death, it's much more important than that.

Return to Top

Moderator:  Andy_Z, John Burnett