Here we go changing the changes again! On December 29, 2010, President Obama signed into law H.R.6398. This requires the FDIC to include Interest on Lawyers Trust Accounts (IOLTAs) within the definition of noninterest-bearing transaction accounts. This, just a few weeks after it was removed from the definition and unlimited coverage! So, if you’ve already notified your IOLTA depositors that their unlimited deposit insurance ends on December 31, 2010, be prepared that you may want to provide a revised notice (optional) advising that IOLTAs WILL receive unlimited insurance coverage as noninterest-bearing transaction accounts for two years (ends on December 31, 2012).
As for the lobby/website notices that you may have already updated, that language will need to be revised as well. The FDIC will be issuing guidance on this requirement as well as model language for the lobby/website notices required by 12 CFR § 330.16. Stay tuned.
Change is the new norm . . . expect it; embrace it . . . Happy New Year!
Deb joined Banker’s Compliance Consulting with twenty years of experience in the banking industry. Her past positions include teller, credit review analyst, assistant financial officer, BSA Officer, Compliance Officer, and Director of Compliance. She has worked for both a small community bank and a large billion-dollar bank.
Deb has Associate Degrees in Business Management and Accounting. She is a graduate of the American Bankers Association National Graduate School of Compliance Management, an honors graduate of Schools of Banking Compliance School, and a graduate of Schools of Banking Advanced School of Banking. Deb’s considerable knowledge and experience make her a valuable member of the Banker’s Compliance Consulting Team. Deb is a Certified Regulatory Compliance Manager (CRCM) and a Certified Anti Money-Laundering Specialist (CAMS).
Deb loves to spend her free time cycling, running, kayaking and weight lifting with her husband. Between them, they have three adult children and six grandchildren. Other interests include anything outdoors and anything she hasn’t done or seen yet!