Fil-9-2009 deals with FDIC issurance for failed institutions and FIL-39-2009 deals with disclosure requirements for SWEEP Accounts under 9-2009.

We had created a disclosure outlining unlimited insurance for non interest bearing accounts and combined that with the SWEEP disclosure mandated by FIL 39-2009. Now that unlimited insurance will no longer be the case, we are modifying the Sweep disclosure. Has anyone else had to update their SWEEP disclosures? There is no model language out there.

bump

If you have a "joint" sweep disclosure notice to satisfy FDIC Regulations 330.16(c)(3) and 360.8(e), why don't you just delete the language relating to the 330.16(c)(3) requirements [dealing with unlimited insurance coverage]? If you do that, then your sweep disclosure notice should just pertain to 360.8(e).

Presumably, the language you inserted in your joint sweep disclosure notice was reviewed by appropriate compliance and/or legal reviewers to insure it satisfied both regulations. If that's the case, why not continue to use what you have been using to satisfy the 360.8(e) disclosure requirements - without including the 330.16(c)(3) disclosure language?