Disclosure Requirements of the Dodd-Frank Deposit Insurance Provision
24. How are depositors notified of the temporary unlimited insurance coverage for noninterest-bearing transaction accounts?
Each IDI that offers noninterest-bearing transaction accounts must have posted, prominently, a copy of the following notice (“Dodd-Frank Notice”) in the lobby of the IDI’s main office, in each domestic branch, and, if it offers internet deposit services, on its website:
NOTICE OF CHANGES IN TEMPORARY FDIC INSURANCE
COVERAGE FOR TRANSACTION ACCOUNTS
All funds in a “noninterest-bearing transaction account” are insured in full by the Federal Deposit Insurance Corporation from December 31, 2010, through December 31, 2012. This temporary unlimited coverage is in addition to, and separate from, the coverage of at least $250,000 available to depositors under the FDIC’s general deposit insurance rules.
The term “noninterest-bearing transaction account” includes a traditional checking account or demand deposit account on which the insured depository institution pays no interest. It also includes Interest on Lawyers Trust Accounts (“IOLTAs”). It does not include other accounts, such as traditional checking or demand deposit accounts that may earn interest, NOW accounts and money-market deposit accounts.
For more information about temporary FDIC insurance coverage of transaction accounts, visit www.fdic.gov.
25. Is the FDIC supplying signage with the amended Dodd-Frank Notice, or do IDIs have to print their own signs?
The FDIC will not be providing signage for the amended Dodd-Frank Notice. IDIs must print their own signage using the required language.
26. Can IDIs amend the text of the Dodd-Frank Notice?
No. IDIs must utilize the specific language provided in FAQ 24 for the Dodd-Frank Notice to be posted in IDIs’ main offices, domestic branches and websites.
27. Can the font or formatting of the Dodd-Frank Notice be modified?
Yes. There is no specified font or formatting requirement for the Dodd-Frank Notice. The notice should be prominent, clear and conspicuous, so that it stands out and can be read by customers from a few feet away.
28. Can an IDI include its logo or brand symbol in the Dodd-Frank Notice?
29. For IDIs that offer internet banking services, does the entire Dodd-Frank Notice have to appear on the IDI’s homepage?
No. The Dodd-Frank Notice on an IDI’s website can either be prominently posted in full on the IDI’s home page or made available through a link designed to bring attention to the importance of the information. As an example, “Important Disclosure Regarding Deposit Insurance on Noninterest-bearing Transaction Accounts,” with a link to the full Dodd-Frank Notice, would be appropriate.
30. For how long must the Dodd-Frank Notice remain posted?
The Dodd-Frank Notice must be posted by all IDIs through December 31, 2012, when the temporary unlimited deposit insurance for noninterest-bearing transaction accounts expires, as provided by the DFA.