Instructions for New Items Associated with the FDIC's Transaction Account
Guarantee Program
Consolidated Reports of Condition and Income (Call Report) (FFIEC 031 and
041), Schedule RC-O, Memorandum items 4.a and 4.b
Thrift Financial Report, Schedule DI, items DI570 and DI575
Report of Assets and Liabilities of U.S. Branches and Agencies of Foreign
Banks (FFIEC 002), Schedule O, Memorandum items 6.a and 6.b
General Instructions: Noninterest-bearing Transaction Accounts (as Defined in
Part 370 of the FDIC's Regulations) of More Than $250,000
NOTE: The items below for the amount and number of noninterest-bearing
transaction accounts of more than $250,000 are to be completed – beginning
in the reports for December 31, 2008 – only by those institutions that
have opted to participate in the FDIC's Transaction Account Guarantee
Program.
Report in the appropriate subitem the amount outstanding and the number of
noninterest-bearing transaction accounts with a balance on the report date of more
than $250,000. An institution may exclude custodial or escrow noninterest-bearing
transaction accounts with a balance of more than $250,000 that are fully insured
because of "pass-through" insurance coverage. An institution may also exclude
amounts over $250,000 in noninterest-bearing transaction accounts that are otherwise
insured under joint account relationships or other existing provisions of the FDIC's
deposit insurance rules to the extent that these amounts can be determined by the
institution and fully supported in the institution's workpapers for this report. An
institution is not required to make a determination of amounts otherwise insured but
may do so at its option.
For purposes of Schedule RC-O, Memorandum items 4.a and 4.b; Schedule DI, items DI570
and DI575; and Schedule O, Memorandum items 6.a and 6.b; and the FDIC's Transaction
Account Guarantee Program, the term ''noninterest-bearing transaction account''
means a transaction account as defined in Federal Reserve Regulation D that is:
(1) Maintained at an insured depository institution (in a domestic office or an
insured branch in Puerto Rico or a U.S. territory or possession);
(2) With respect to which interest is neither accrued nor paid; and
(3) On which the insured depository institution does not reserve the right to require
advance notice of an intended withdrawal.
Thus, the term "noninterest-bearing transaction account" includes all demand
deposits, including certified checks and official checks (such as cashiers' checks
and money orders) drawn on the reporting institution.
In addition, for purposes of Schedule RC-O, Memorandum items 4.a and 4.b; Schedule
DI, items DI570 and DI575; and Schedule O, Memorandum items 6.a and 6.b; and the
Transaction Account Guarantee Program, the term "noninterest-bearing transaction
account" also includes:
(1) Accounts commonly known as Interest on Lawyers Trust Accounts (IOLTAs) (or
functionally equivalent accounts); and
(2) Negotiable order of withdrawal (NOW) accounts with interest rates no higher than
0.50 percent for which the insured depository institution at which the account is
held has committed to maintain the interest rate at or below 0.50 percent.1
For purposes of Schedule RC-O, Memorandum items 4.a and 4.b; Schedule DI, items DI570
and DI575; and Schedule O, Memorandum items 6.a and 6.b; and the FDIC's Transaction
Account Guarantee Program, a "noninterest-bearing transaction account" does not
include, for example, a money market deposit account (MMDA) as defined in Federal
Reserve Regulation D.
Account features such as the waiver of fees or the provision of fee-reducing credits
do not prevent an account from qualifying as noninterest-bearing as long as the
account is otherwise noninterest-bearing.
In determining whether funds are in a noninterest-bearing transaction account for
purposes of Schedule RC-O, Memorandum items 4.a and 4.b; Schedule DI, items DI570
and DI575; and Schedule O, Memorandum items 6.a and 6.b; and the Transaction Account
Guarantee Program, the FDIC will apply its normal rules and procedures under Section
360.8 of the FDIC's regulations for determining account balances at a failed insured
depository institution. Under these procedures, funds may be swept or transferred
from a noninterest-bearing transaction account to another type of deposit or
nondeposit account. Except as described in the following sentence, unless the funds
are in a noninterest-bearing transaction account after the completion of a sweep
under Section 360.8, the funds will not be guaranteed under the Transaction Account
Guarantee Program and they should not be reported in Schedule RC-O, Memorandum items
4.a and 4.b; Schedule DI, items DI570 and DI575; and Schedule O, Memorandum items
6.a and 6.b. However, in the case of funds swept from a noninterest-bearing
transaction account to a noninterest-bearing savings deposit account as defined in
Federal Reserve Regulation D, the FDIC will treat the swept funds as being in a
noninterest-bearing transaction account. If the sum of the swept funds in the
noninterest-bearing savings deposit account plus any amount remaining in the related
noninterest-bearing transaction account is $250,000 or more, this sum should be
reported in Schedule RC-O, Memorandum item 4.a; Schedule DI, item DI570; and
Schedule O, Memorandum item 6.a; and the swept funds and the related
noninterest-bearing transaction account should be reported as one account in
Schedule RC-O, Memorandum item 4.b; Schedule DI, item DI575; and Schedule O,
Memorandum item 6.b.
Include public funds held in noninterest-bearing transaction accounts of more than
$250,000 whether or not they are collateralized with pledged securities or other
pledged assets.
Schedule RC-O, Memorandum item 4.a; Schedule DI, item DI570; and Schedule O,
Memorandum item 6.a: Amount of noninterest-bearing transaction
accounts of more than $250,000
Report the aggregate balance of all noninterest-bearing transaction accounts (as
defined in the General Instructions above) with a balance on the report date of more
than $250,000. This amount should represent the total of the balances of the
noninterest-bearing transaction accounts enumerated in Schedule RC-O, Memorandum
item 4.b; Schedule DI, item DI575; and Schedule O, Memorandum item 6.b, below.
Schedule RC-O, Memorandum item 4.b; Schedule DI, item DI575; and Schedule O,
Memorandum item 6.b: Number of noninterest-bearing transaction accounts of more
than $250,000
Report the total number of noninterest-bearing transaction accounts (as defined in
the General Instructions above) with a balance on the report date of more than
$250,000.
1 A NOW account with an interest rate
above 0.50 percent as of November 21, 2008, may be treated as a noninterest-bearing
transaction account for purposes of the Transaction Account Guarantee Program if the
insured depository institution at which the account is held reduces the interest
rate on that account to 0.50 percent or lower before January 1, 2009, and commits to
maintain that interest rate at no more than 0.50 percent at all times through
December 31, 2009.
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