Small Entity Compliance Guide related to Simplification of Deposit Insurance Rules for Trust and Mortgage Servicing Accounts

Summary:

On January 28, 2022, the Federal Deposit Insurance Corporation (FDIC) published a final rule to amend the deposit insurance regulations for trust accounts and mortgage servicing accounts. The changes are intended to make the deposit insurance rules easier to understand for depositors and bankers, facilitate more timely insurance determinations for trust accounts in the event of a bank failure, and enhance consistency of insurance coverage for mortgage servicing account deposits. The final rule will take effect on April 1, 2024, providing depositors and banks more than two years to prepare for the changes in coverage.

The FDIC is adding a Small Entity Compliance Guide to its website to assist insured depository institutions and community banking organizations in understanding and preparing for the changes in deposit insurance coverage.

Statement of Applicability: The contents of, and material referenced in, this FIL apply to all FDIC-insured financial institutions.

Highlights:

• The FDIC is updating its Banker Resources Guide Deposit Insurance Page with the Small Entity Compliance Guide (Community Bank Information) to promote understanding of the regulations.
• The final rule amends the deposit insurance regulations by merging the revocable and irrevocable trusts categories into one category.
• The final rule amends the regulation to expand the current per-borrower coverage of up to $250,000 to include any funds paid into the account to satisfy the principal and interest obligation of the mortgagors to the lender.
• Some depositors within excess of $1.25 million in trusts deposits at a particular IDI may want to make changes given the new coverage limits that take effect on April 1, 2024.