4000 - Advisory Opinions
Insurance Coverage of Accounts Held by Bankruptcy Trustee
November 9, 1988
Walter P. Doyle, Counsel
In response to your October 21 letter, this will confirm that deposits in an FDIC-insured bank by a bankruptcy trustee pursuant to 11 U.S.C. 345 are insured up to $100,000 as to each bankruptcy estate having an interest in such deposits.
This coverage is separate from and additional to any insurance limits applicable to deposits made in the same bank by the trustee in his or her individual capacity or by any bankruptcy debtor or creditor; and the $100,000 limit for each bankruptcy estate applies whether a separate deposit is established by each estate or the funds of several estates are commingled in the same deposit. Such separate coverage is likewise applicable whether a deposit account is styled with the trustee's name and title preceding or following the name of the estate. In fact, our regulations require only that the account records indicate the existence of the fiduciary relationship and would not even require naming the bankruptcy estate, so long as the trustee's records show the interest of each estate in the deposit.