In our November 21, 2012, blog, we alerted you to the fact that the unlimited deposit insurance coverage for non-interest bearing transaction accounts, including Interest on Lawyer Trust Accounts, is set to expire December 31, 2012. Well, it appears that it will. A bill was introduced to extend this unlimited insurance coverage; however, it was defeated in the Senate on December 13, 2012.
Even with this new development, you are still not “required” to provide advance notification to affected customers. It is; however, strongly encouraged. Please refer to FIL-45-2012 and the Frequently Asked Questions and Answers for guidance. Since there are no “requirements”, you have some latitude but customer service is important too.
Also, don’t forget to remove any lobby signs and/or notices on your website due to this expiration.