Alert October 21, 2008

FDIC Makes Available Updated Trust Examination Manual

The FDIC made available an updated version of its Trust Examination Manual (the “Manual”).  Revisions to the Manual include guidance concerning: SEC/FRB Regulation R and Gramm-Leach-Bliley Act exceptions from the definition of “broker” under the Securities Exchange Act of 1934; IRS and Department of Labor treatment of health savings accounts and abandoned employee benefit plans; and changes enacted in the Pension Protection Act of 2006, and their impact on IRAs and other ERISA-governed employee benefit plans.