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Questions and Answers
1.
How can I qualify for more than the SMDIA, currently $250,000, in FDIC insurance
coverage?
The FDIC provides separate
insurance coverage for a depositor’s
funds at the same insured bank if the funds are held in different
ownership categories. To qualify for this expanded coverage, the
requirements for
insurance coverage in each ownership category must be met.
The example below illustrates
how a family of four – a husband and
wife with two children – could qualify for up to $3 million in FDIC
coverage at one insured bank. This example assumes that the funds
are in qualified deposit products at an insured bank and these are
the only accounts
that the family has at the bank.
| Example: Insurance coverage for a family of four with
deposit accounts in multiple ownership categories |
Account Title |
Account Ownership Category |
Owner(s) |
Beneficiary(ies) |
Maximum Insurable Amount |
| Husband |
Single Account |
Husband |
|
$ 250,000 |
| Wife |
Single Account |
Wife |
|
250,000 |
| Husband IRA |
Certain Retirement
Account |
Husband |
|
250,000 |
| Wife IRA |
Certain Retirement
Account |
Wife |
|
250,000 |
| Husband & Wife |
Joint
Account |
Husband
& Wife |
|
500,000 |
| Husband POD |
Revocable Trust
Account |
Husband |
Wife |
250,000 |
| Wife POD |
Revocable Trust
Account |
Wife |
Husband |
250,000 |
| Husband & Wife
Living Trust |
Revocable Trust
Account |
Husband
& Wife |
Child
1
Child
2 |
1,000,000 |
| Total |
|
|
|
3,000,000 |
| Amount Insured |
|
|
|
3,000,000 |
| Amount Uninsured |
|
|
|
$ 0 |
Explanation:
Single
Account Ownership Category: The FDIC combines all single accounts
owned by the same person
at the
same bank and insures the total up to $250,000.
The Husband’s single account deposits do not exceed $250,000 so his
funds are fully insured. The same facts apply to the Wife’s single
account deposits. Both accounts are fully insured.
Certain Retirement
Account Ownership Category: The FDIC adds together
all certain retirement accounts owned by the same person at the same bank
and insures the total up to $250,000. The Husband and Wife each have an
IRA deposit at the bank with a balance of $250,000. Because each account
is within the insurance limit, the funds are fully insured.
Joint Account
Ownership Category: Husband and Wife have one joint account at the bank. The FDIC
combines
each co-owner’s shares of all joint
accounts at the bank and insures each co-owner’s total up to $250,000.
Husband’s ownership share in all joint accounts at the bank equals ½ of
the joint account or $250,000, so his share is fully insured. Wife’s
ownership share in all joint accounts at the bank equals ½ of the
joint account or $250,000, so her share is fully insured.
Revocable Trust Account
Ownership Category: To determine insurance coverage of revocable
trust accounts,
the FDIC first determines the amount of the
trust’s deposits belonging to each owner. In this example:
-
Husband’s share = $750,000 (100% of the Husband’s POD account
naming Wife as beneficiary and 50% of the Husband and Wife Living
Trust account identifying Child 1 and Child 2 as beneficiaries)
-
Wife’s share = $750,000 (100% of the Wife’s POD account naming
Husband as beneficiary and 50% of the Husband and Wife Living Trust
account identifying Child 1 and Child 2 as beneficiaries)
Second, the FDIC determines the number of beneficiaries for each
owner. In this example, each owner has three different beneficiaries
(Spouse, Child 1 and Child 2). When a revocable trust owner
has five or fewer different
beneficiaries, the owner is insured up to $250,000 for each
different beneficiary. Husband’s share of the revocable trust deposits is insured up to
$750,000 ($250,000 times three beneficiaries = $750,000). Wife’s
share of the revocable trust deposits is insured up to $750,000 ($250,000
times three beneficiaries = $750,000). Death of an Account Owner or Beneficiary
2. What happens to insurance coverage after an account owner
dies?
The FDIC insures a deceased person's accounts as if the person
were still alive for six months after the death of the account
holder. During
this grace period, the insurance coverage of the owner's accounts
will not change unless the accounts are restructured by those
authorized to
do so. Also, the FDIC will not apply this grace period if it
would result in less coverage.
3. How does the death of a beneficiary of an informal revocable
trust (e.g., POD account) affect insurance coverage?
There is no grace period if the beneficiary of a POD account
dies. In most cases, insurance coverage for the deposits would
be reduced immediately.
For
example: A mother deposits $500,000 in a POD account at
an insured bank with her two children named as the beneficiaries
in the account
records of the bank. While the owner and both beneficiaries
are alive, the account
is insured up to $500,000 ($250,000 times two beneficiaries
= $500,000). If one beneficiary dies, insurance coverage
for the mother’s POD
account is immediately reduced to $250,000 ($250,000 times one beneficiary
= $250,000).
4. How does the death of a beneficiary of a formal revocable
trust affect the insurance coverage?
Like informal revocable trusts, the six-month grace period
does not apply to the death of a beneficiary named in a formal
revocable trust account.
However, the terms of the formal revocable trust may provide
for a successor beneficiary or some other redistribution
of the trust
deposits.
Depending
on these terms, the insurance coverage may or may not change.
Merger of Insured
Banks
5. What happens to my insurance coverage if I have deposits
at two insured banks that merge?
When two or more insured banks merge, deposits from the
assumed bank are separately insured from deposits at
the assuming bank for at least
six months after the merger. This grace period gives
a depositor
the opportunity to restructure his or her accounts, if
necessary.
CDs from
the assumed bank are separately insured until the earliest maturity date
after the end of the six-month
grace period. CDs
that mature during the six-month period and are renewed
for
the same term and in the
same dollar amount (either with or without accrued
interest) continue to be separately insured until the first
maturity date after the six-month
period. If a CD matures during the six-month grace
period
and is renewed
on any other basis, it would be separately insured
only until the end of the six-month grace period.
Fiduciary Accounts
6. What are fiduciary accounts?
Fiduciary accounts are deposit accounts owned by one
party but held in a fiduciary capacity by another
party. Fiduciary relationships may include,
but are not limited to, an agent, nominee, guardian,
executor
or custodian. Common fiduciary accounts include
Uniform Transfers to
Minors
Act accounts,
escrow accounts, Interest On Lawyer Trust Accounts
and deposit accounts obtained through a broker.
7. What are the FDIC disclosure requirements
for fiduciary accounts?
The fiduciary nature
of the account must be disclosed in the bank's deposit account records
(e.g., "Jane Doe as Custodian for Susie Doe" or "First
Real Estate Title Company, Client Escrow Account").
The name and ownership interest of each owner must
be ascertainable from the deposit account
records of the insured bank or from records
maintained by the agent (or by some
person or entity that has agreed to maintain records for the agent).
Special disclosure rules apply to multi-tiered
fiduciary relationships. If an agent pools
the deposits of
several owners into one account
and the disclosure rules are satisfied, the
deposits of each owner will be insured
as that owner's deposits.
8. How does the FDIC insure funds deposited
by a fiduciary?
Funds deposited by a fiduciary on behalf
of a person or entity (the owner) are insured
as the
deposits
of the owner if
the
disclosure requirements
for fiduciary accounts are met.
9. Are funds
deposited by a fiduciary insured separately from an owner's
other deposit accounts at the
same bank?
Funds deposited by a fiduciary on behalf
of a person or entity (the owner)
are added to any
other
deposits the owner
holds in the same ownership category
at the same bank and insured up to the
applicable limit.
For example: A broker
purchases a CD for $250,000 on a customer's behalf at
ABC Bank. The customer
already has a checking
account
in his or her name at ABC Bank for
$15,000. The two accounts are added together and
insured up to $250,000 in
the
single ownership account
category.
Since
the customer’s single ownership deposits total $265,000, $15,000
is uninsured.
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