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4000 - Advisory Opinions

Deposit Insurance Coverage For Step-Children: Testamentary Trust Accounts


November 7, 1989

Claude A. Rollin, Senior Attorney

This is in response to your letter to Mr. Roger Hood, dated November 1, 1989, and our subsequent telephone conversation, concerning the issue of whether step-children are considered qualifying beneficiaries by the FDIC for the purpose of determining, pursuant to 12 C.F.R. § 330.3, the deposit insurance coverage for testamentary trust accounts.

This will confirm the Legal Division's current position that a step-child is a "child" for the purposes of determining the insurance coverage provided for testamentary accounts pursuant to 12 C.F.R. § 330.3. While this represents the current thinking of the Legal Division staff, you should be aware that this opinion, like all other staff opinions, is not binding on the FDIC or its Board of Directors.

You should also be aware that we are currently drafting amendments to the FDIC's deposit insurance regulations which may or may not affect the opinion expressed herein. These amendments are being prepared pursuant to section 402 of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (the "FIRRE Act") which requires the FDIC to promulgate uniform deposit insurance regulations, to govern the deposit insurance for deposits in all banks and savings and loan institutions, no later than May 5, 1990.

I trust that this has been responsive to your inquiry.

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