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4000 - Advisory Opinions

Insurance Coverage for Certain Deposit Notes


April 1, 1992

Alan J. Kaplan, Senior Counsel

This responds to your March 27 letter, which asks whether certain "deposit notes" issued by *** (and described in an Offering Circular dated December 10, 1991 and an Offering Circular Supplement dated December 11, 1991) are insured by the FDIC.

According to the offering materials you sent me, as well as a letter from ***, the bank holds these deposit notes out to the public as insured deposits, reports them as deposits on its quarterly call reports filed with its Federal regulators, and pays insurance assessments to the FDIC on the deposit notes.

Based on these representations and on my review of the offering materials, it is my opinion that these deposit notes meet the statutory definition of "deposit" under the Federal Deposit Insurance Act (12 U.S.C. § 1813(l)) and therefore constitute deposits insured by the FDIC up to the limits provided by law.

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