Signature Card Compliance (FDIC)

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Question:

We need more information about compliance when it comes to signature cards. We use add and remove forms for account owners, signers, and beneficiaries when the owner wants to make changes after opening their account rather than printing a whole new signature card that all account owners would have to re-sign. Are these compliant with FDIC requirements when it comes to distinguishing what type of insurance coverage they would have?

Answer:

You should review part 330, https://www.fdic.gov/regulations/laws/rules/2000-5400.html#fdic2000part330

The FDIC wants a signature card but does not define what one is, or what it is not. It does want, but again is not required, the type of account, single, joint, etc. So having an original form and amendments will be fine. The difficulty comes in when one or more of those amendments cannot be found on that 15 year old account after a merger and those employees are retired who handled those. The point is, the more items that comprise your signature card for an account, the greater the chance of an error.