We just had an FDIC examiner ask us if we have notified our TAG customers to let them know the program expires at the end of the year? Is there a notification requirement that I am missing?

I am not aware of any such notification. I thought that the signage in the branch was the only notification necessary.

We just had an FDIC Exam in August and was not asked that question.

Compliance4521. An appropriate answer to the examiner would be, "Gee, I wasn't aware of such a requirement. Can you show me what I missed?" The examiner will come up empty.

Of course, our friends at the FDIC may decide that such a notice is needed. If that's the case, they'll need to do something fast, since it's unlikely they could meet the 12/31/12 deadline taking all the required hurdles to proposing and finalizing a regulation amendment.