Alert July 14, 2009

FDIC Issues FAQs Regarding New Sweep Account Disclosure Requirement

The FDIC issued FAQs regarding the new disclosure requirements for certain sweep accounts.  Among other things, the FAQs clarify the types of sweep accounts subject to the disclosure requirements.  The FAQs also clarify the timing of the required disclosures:  for accounts in effect on July 1, 2009, the disclosures must be provided within 60 days after July 1, 2009 (i.e., no later than September 1, 2009) and at least annually thereafter; and for accounts established after July 1, 2009, the disclosures must be provided at the time the sweep account agreement is entered into.  Click here for the FAQs.