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#968018 - 06/03/08 02:36 PM FDIC Ins coverage question
babyboomer Offline
Member
Joined: Sep 2007
Posts: 69
Oklahoma
On our signature cards for deposit accounts we document in the account ownership section if the account is a POD and identify all beneficiary's by name. However on our CIF we do not put this information in the title as we have had customers complain that they don't want to see that on their statements.

A question has been raised because the FDIC guidelines indicate that the "account title" must manifest the grantor's intention upon his death to pass the funds to the named beneficiary.

The question is: is the extended FDIC coverage there for the beneficiaries since it is on the signature card contract only but not in the CIF?

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#968128 - 06/03/08 03:25 PM Re: FDIC Ins coverage question babyboomer
Ski Offline
Platinum Poster
Joined: May 2003
Posts: 639
South Louisiana
From the "Gold Book":

The FDIC relies upon the deposit records of the bank to determine the ownership of an account, and thus the amount of coverage available. If the records are clear and not ambiguous, those records shall be considered binding on the depositor, and the FDIC shall consider no other records on the manner in which the funds are owned.

Deposits account records include:

- Signature cards
- CD's and passbooks
- Account ledgers and computer reocrds that relate to the bank's deposit-taking function
- Corporate resolutions authorizing accounts in the possession of the bank
- Official items
- Other books and records of the bank.

So it seems that the first resource would be what is contained on the signature card (deposit contract).

Hope this helps.

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#968187 - 06/03/08 03:56 PM Re: FDIC Ins coverage question Ski
babyboomer Offline
Member
Joined: Sep 2007
Posts: 69
Oklahoma
Thanks - just needed confirmation of what I thought was correct.
Second question - When we have an account for a revocable living trust, the trustees are named on the signature card and in the account title in CIF. For FDIC expanded coverage do we have to name the trust beneficiaries on the signature card or would the FDIC look to the depositor to provide the trust agreement to evidence the beneficiaries for expanded coverage? If we did name the beneficiaries, the depositor could change the trust beneficiaries without knowledge and what we had documented on the signature contract could be wrong in the future. My understanding from what I am reading about this kind of a trust account indicates that we do not have to name the beneficiaries on the signature contract but the trust must name them. Correct or not?

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#968267 - 06/03/08 04:55 PM Re: FDIC Ins coverage question babyboomer
MN Banker Offline
Platinum Poster
Joined: Aug 2006
Posts: 980
If it is a formal revocable trust, the beneficiaries must be listed in the trust agreement, and do not have to be listed on the sig card.

Here is a really good guide for trust insurance
Last edited by MN Banker; 06/03/08 04:57 PM.
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#968314 - 06/03/08 05:38 PM Re: FDIC Ins coverage question MN Banker
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
I was told by FDIC that we should include POD in our account titling on the system to insure it is recognized as a testamentary account. The specific information regarding the beneficiary(ies) will be pulled from the deposit records.

You do not need to name trust beneficiaries in your deposit records, FDIC would look to current trust documentation for that info. Document name of trust and trustee(s) in your account records, including system titling.
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