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4000 - Advisory Opinions

New Rules Do Not Affect Separate Insurance Coverage for Beneficiary's Interest in Decedent's IRA and Beneficiary's Own IRA Held at Same Depository Institution


August 30, 1993

Walter P. Doyle, Counsel

Thank you for your August 19 letter to Mark Mellon inquiring whether changes in deposit insurance rules effective December 19, 1993 would affect the separate coverage up to $100,000 for your own IRA accounts and another $100,000 at the same insured institution for your deceased husband's IRA accounts, which designate you as sole beneficiary.

As indicated in Mr. Mellon's March 21, 1991 letter to you, a surviving beneficiary's present vested and ascertainable interests in a decedent's IRA accounts are insured to $100,000, separately from the additional $100,000 coverage for the beneficiary's own IRA accounts held at the same insured institution. Of course, if the beneficial interest in a decedent's IRA is rolled over into a surviving spouse's IRA or withdrawn and deposited into a non-IRA account at the same institution, then such separate coverage would cease. But so long as the decedent's IRAs remain separate from the surviving beneficiary's, each type would be covered up to a separate $100,000 limit, and this separate coverage applies both before and after the new aggregation rules become effective on December 19, 1993. This is true even though your husband's IRAs at one bank were consolidated into one account designating you as beneficiary of his IRA and using your social security number.

Please let us know if we can be of further help.

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