Changes to FDIC Insurance Changes…Here We Go Again!

Here we go changing the changes again! On December 29, 2010, President Obama signed into law H.R.6398. This requires the FDIC to include Interest on Lawyers Trust Accounts (IOLTAs) within the definition of noninterest-bearing transaction accounts. This, just a few weeks after it was removed from the definition and unlimited coverage! So, if you’ve already notified your IOLTA depositors that their unlimited deposit insurance ends on December 31, 2010, be prepared that you may want to provide a revised notice (optional) advising that IOLTAs WILL receive unlimited insurance coverage as noninterest-bearing transaction accounts for two years (ends on December 31, 2012).

As for the lobby/website notices that you may have already updated, that language will need to be revised as well. The FDIC will be issuing guidance on this requirement as well as model language for the lobby/website notices required by 12 CFR § 330.16. Stay tuned.

Change is the new norm . . . expect it; embrace it . . . Happy New Year!

Published
2011/01/04
Deb Irving

David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

Recent Posts

Understanding Customer Risk Profiles

Section 1071: Business Owner Status

Auditing Your BSA/AML Program