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!