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Mailing Notices to Customers about Dodd-Frank

Do we need to post a notice concerning the Dodd-Frank Reform Act Section 343 concerning FDIC coverage? Do we need to mail a disclosure to our depositors with NOW or IOLTA accounts concerning the standard maximum deposit insurance amount of $250,000?

Answer by Jim Bedsole: Yes and Yes. You can find detailed information in FDIC FIL-76-2010 available here and FIL-2-2011, here.

The regulation requires both a lobby notice and a mailing to all customers with NOW accounts who had unlimited balance coverage under the old TAG program because that went away for those accounts on December 31. Originally, IOLTA accounts were to be notified as well, but Congress acted at the eleventh hour and legislation was enacted on December 29, 2010 to include IOLTAs under the new temporary unlimited insurance coverage for FDIC-insured institutions. Banks were advised that if they had not yet notified IOLTA customers, they didn't need to do so.

On January 18, 2011, the FDIC approved a final rule amending its Deposit Insurance Coverage rules at 12 CFR Part 330 to include IOLTAs. FDIC-insured institutions have until February 28, 2011 to update their lobby and website postings concerning the temporary coverage with new verbiage required by Section 330.16(c)(1). Institutions that did notify IOLTA accounts as required by the old regulation wording are encouraged, but not required, to let those customer know their accounts have been included.


Answer by John Burnett: Just in case you forgot, the old TAG program notices in bank lobbies and on websites should have been removed at the close of business on December 31, 2010. If you haven't done it yet, make sure you take care of it right away.

First published on 1/31/11

First published on 01/31/2011

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