It struck me as strange that they are emphasizing the removal of the OLD notices from lobbies and Web sites, but not mandating that we place NEW notices in their place. I would also like to do that. Can anyone think of a good reason why we shouldn't?

The fact that you aren't required to post notices announcing the end of the unlimited insurance provision doesn't mean you can't post something. I'd recommend using the wording from the targeted notices suggested by the FDIC if you do post.

Wouldn't we have to post the notice that accounts are insured for up to $100,000?

FDIC insurance was permanently increased to 250,000.00 when Dodd-Frank was signed (7/21/10), but non-interest bearing accounts kept the temporary unlimited insurance through 12/31/12. When the clock strikes midnight on New Year's Eve, all account ownership categaories will have $250,000.00 in insurance.

errr! I knew that - had a brain cramp! but do we post the $250K sign?

Yes.

Uh, you should have that sign up at your teller windows already.

Two questions:
is a notice to the customer required about the expiraton?
and
without getting into financial advising, we have customers asking what do we recommend they do with $1million deposits on non-interest bearing accounts. They don't want to move the account and we dont want to lose the customer.

1. No, but highly recommended by the FDIC.

2. Describe any alternatives your bank may offer, i.e. repos, etc.

3. You need to refer them to their financial advisor.

Optional:

3. Recommend they have their heads examined for having $1MM in non-interest bearing account.

Your bank might look into CDARS, which currently allows large dollar amounts to be shared among participating institutions, with full FDIC coverage, via a form of "CD Participation." www.cdars.com.

I've heard rumors that CDARS may consider offering a similar product for transaction account balances, but thus far I see nothing about it on their website.

As for the notice, the FDIC guidance says it's not required, but goes on to strongly recommend it.

"Highly recommended" is good enough for me! Does anyone have a good blurb I can use for the notice, which by the way, we are going to include on the December statements?
so have to get on this right away. Thanks!

The FDIC provided one in their FIL (Randy posted a link on first page of this thread).

If you check out the FDIC's FIL, you'll see the language they recommend. There are two versions. One is shorter, designed for statement messages, but several posters have said there are still too many characters used. So take that version and tweak it a bit to shorten it if necessary, keeping the meaning intact.

Is there some material available on the internet that we can give to the customer to help them properly structure accounts so they can get the most coverage possible?

There is always the FDIC's EDIE tool at http://www.fdic.gov/edie/

The FDIC has a whole page of helpful links addressing this information, including a link to the FAQ on the expiration of the TUC (Temporary Unlimited Coverage) for NIBTAs. You'll find that page at http://www.fdic.gov/deposit/deposits/index.html

I am running into the same problem with the character restriction for my statements. My other alternative is to mail out the suggested language provided by the FDIC.

Anyone care to share your shortened (statement friendly) version of the notice?

For those that are posting the "notice" on their websites - Are you posting it on the same page as the original notice of the unlimited FDIC coverage for non-interesting bearing accounts or placing it on a separate page and drawing attention to it on your "HOME" page?

We removed the original notice as the new notice states the insurance coverage will end 12/31/12.

Has anyone discussed only notifying customers that have balances of $250,000 or over in a non-interest bearing account. This is what my bank has decided to do, because those accounts are the only ones that will be affected. Not what I recommended, but I am only the Complaince Officer.

I hasten to suggest that I might be a customer with a $50,000 balance who receives on January 15, 2013, a fat payout from the state lottery, and I need to park the funds in my non-interest bearing checking for a few days while I decide where to invest/donate the money. How am I going to know that most of my money isn't FDIC-insured?

(By the way, do you know what the winning numbers will be?)

I wouldn't think this would work because a customer who has less than $250k could make a large deposit between now and the end of the year.

We have discussed only notifying customers with aggregate balances of 100m and up, but have not made any decisions yet.

What if your customer is the beneficiary of a fiduciary account with pass through deposit insurance coverage and the funds are insured in the same ownership category? When aggregated, the deposits may exceed your designated amount for sending notices.

For example, assume a customer has $75,000 in a non-interest bearing transaction account in their name only (either individual or business). Further assume that customer is involved in a litigation matter and their attorney also banks with you. The attorney's IOTLA account will also have the benefit of unlimited coverage through 12/31/12 and has pass-through coverage because it is a fiduciary account.

Now assume your customer settles their lawsuit and their attorney places their settlement proceeds ($200,000) into the attorney's IOLTA account pending the signing of the necessary settlement documents. If unlimited coverage expires at the end of the year, then your customer will have $250,000 insured and $25,000 uninsured out of the $275,000.

You won't know about the beneficial ownership of the funds held in the attorney's IOLTA account (or any other fiduciary account with pass through coverage where the funds are held in non-interest bearing transaction accounts).

If you ignore the interaction of pass-through coverage on fiduciary accounts and the need to aggregate deposits held in the same ownership category (the same holds true for joint accounts where the non-primary tax ID customer is on multiple joint accounts with different individuals in non-interest bearing transaction accounts), then you may not send a notice out to everyone who may be adversely affected by the termination of unlimited coverage.

The Senate is set to vote on the extension of TAG today.

Pushed back until today at 2:15pm due to weather yesterday. Will definitely be interesting to see what happens.