Temporary Unlimited Coverage for Noninterest-Bearing Transaction Accounts......are we required to send out notices to our customers that this is expiring? If so, is a statement message or stuffer sufficient?

We were opting for the statement message, but it is too long! Can we alter the model language in any way and still be in compliance?

The FDIC wording is suggested; it's not mandatory. There's not even a requirement that you provide the notice at all. So if you want to provide a notice, try to get across the same message the FDIC notice provides in fewer words, and you should be just fine.

We will be adding it to our statements. Is anyone posting this notice of the expiration on their website too?

Is there any chance the lawmakers will backtrack and extend the unlimited coverage beyond year-end?

Although there always the possibility, however slight, I think the odds are really heavy that Congress won't act.

Only if members of Congress and the Senate lose their own money, then they most likely will -- just like they did when they backtracked the $100k to $250k change, which included the failure of Indy Mac, where many politicians had money deposited and thus gave themselves an extra $150k of protection after-the-fact, just to line their own pockets.

Thanks guys, I just didn't want to inform our customers of the change and then have to reverse what I disclosed if it was likely the change would not occur.

We are printing as a statement message and have also updated our website with the model language.

amyinred where did you put the notice on your website?

If you put a tease on your front page for the notice required by section 330.16(c) of the FDIC regulations and put that Notice on a linked page, that would seem to be an ideal place for the sunset notice, but added below the 330.16 notice.

Folks are putting a notice on their websites? Thought was would only remove the current language from our site and that would be sufficient. We're mailing a letter to those affected customers for notification.

Seems Sen. Reid has some ideas on extending the TAG for two years, if he can get some help. See ABA news bytes today.

I seen the ABA Newsbytes on Sen Reid's bill. So lets see, the FDIC says we should give customers "adequate advance" notice of the change but now we have a bill that could change it! I know that the FDIC notice isn't mandatory but when is the last time an examiner said it was okay not to follow the guidance? I wonder what our customers will think when we have a statement message in December saying its going away and then a statement message in January saying its back!!!!! I know I sound a little cynical (must be a bad day) but does anyone in Washington know what they are doing? But then on the other hand - I should be thankful for job security!

This is what we did last time. Changed at the last minute.

You could indicate in your notice that Congress may act to change the law. Or you could simply wait until Congress adjourns for the holiday break, after which the bill can't pass since Congress won't be in session for the rest of the year.

We are removing our old lobby and website notices (the ones explaining the NIBTA coverage) before opening Wed, 1/2/13. Should we leave up the sunset lobby and website notices for lingering questions or are they ok to remove as well?

If they are notices about the end of the unlimited coverage, they were "encouraged" but never actually required. I see no downside to leaving them up for a while, just in case there are lingering questions.

But, like all regulatory wallpaper, notices like these fade into the background over time. I suggest you set yourself a reminder for the end of January or February to take them down.

Sounds great. Thanks.