FDIC Proposes New Deposit Insurance Training and Disclosure Requirements

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On February 11, 2011 the FDIC proposed new education and disclosure rules related to deposit insurance coverage. Under the proposed rule, every employee of an FDIC-insured bank that has either the authority to open a deposit account or to respond to an inquiry about deposit insurance coverage would be required to complete a deposit insurance training course using online materials provided by the FDIC. New employees would be required to complete this training within 30 days after being hired. Existing employees would be required to complete the training within 60 days of the final rule becoming effective. All covered employees would be required to go through the training on an annual basis.

In addition to this new training requirement, the rule proposes a new affirmative duty on banks to ask every customer opening a new deposit account if that customer has an ownership interest in any other deposit accounts at that bank and, if so, whether the customer’s deposits at the bank exceed deposit insurance coverage limits. If the customer indicates that the deposit insurance limits are exceeded, the bank would be required to provide the customer with a copy of the FDIC’s Deposit Insurance Summary publication.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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