Craig Sent: Friday, November 07, 2008 1:26 PM To: Comments Subject: RIN # 3064-AD37
To whom it may
As stated in the
Interim Rule under theDisclosures
regardingparticipation in the
temporary liquidity guarantee program it states in part Institution must
post a prominent notice in the lobby of its main office and each branchclearly
indicating whether the entity is participatingin the
transaction account guarantee program, i.e. whether it has opted out. If the
entity isparticipating in the
transaction account guarantee program, the notice must also state that funds
in noninterest-bearing transaction accounts at the entity are insured in
full by the FDIC.
A) These disclosures
must be provided in simple,readily
understandable text. B) If the
institution uses sweeparrangements or
takes other actions that result in funds being transferred or reclassified
to an interest-bearing account or nontransaction account, the institution
mustdisclosethose actions to
the affected customers and clearly advise them, in writing, that such
actions will void the FDICs guarantee.
1) Is the institution
required to post the prominent notice in a Loan Production Office (LPO)?
2) TheFDIC should
provide institutions with modellanguage to use
in the prominent notice to ensure clarify and consistency prior tothe12/01/08deadline.
3) As stated under B
abovethe institution must
clearly advise them in writing that such actions will void the FDICs
Does theprominent notice at the
branchadequately cover this
provision as to advisingthecustomer in
writing or is the institution required to provide a separate written notice
from the posted branch notice toeachcustomer thatisaffected bytheirindividualsweeparrangementswhich they can
keep. If a separate notice must be provided, then what are the delivery
methods, such as,bymail, hand out,
email? Please clarify questions.