4000 - Advisory Opinions
Deposit Insurance Coverage Aggregated for Several Accounts
September 2, 1987
Patti C. Fox, Attorney
This will respond to your letter of July 31, 1987, inquiring as to the federal deposit insurance coverage of several accounts.
Section 330.5 of FDIC regulations provides that the deposit accounts of a corporation or partnership engaged in independent activity are insured up to $100,000 in the aggregate. The term "independent activity" is defined as any activity other than one directed solely at increasing insurance coverage. 12 C.F.R. § 330.7. Accounts owned by the same corporation and differentiated solely by the purpose of the funds, such as payroll or operating accounts, would be aggregated together and insured to $100,000.
Based on the limited information in your letter, it appears that *** is the trade name for a grocery business actually owned and operated by ***. Further, *** also appears to be doing business as ***. Assuming that neither *** nor *** is incorporated, then the accounts of both would be added to those held by *** and the total insured to $100,000. If *** were incorporated, then the accounts held in its name would be added together and insured to $100,000 separately from those of ***. Although tax identification numbers do not determine deposit insurance coverage, the fact that all three entities share a common number would seem to support a conclusion that *** and *** are not separately incorporated.