Alert June 15, 2010

FDIC Issues Guidance Deposit Placement Activities

The FDIC issued guidance on what steps insured institutions that collect or place deposits on behalf of customers must take to insure that customers’ deposits are eligible for pass-through insurance when an institution enters into third-party arrangements to collect and place deposits. According to the guidance, banks must (1) maintain records showing that the deposit is eligible for pass through insurance, (2) maintain detailed records of the name and location of the bank receiving the deposits, the owners of the deposits, and the amount, interest rate and maturity date of the deposits, (3) provide customers with the name of the receiving bank and the amount deposited, (4) ensure that marketing materials, customer statements, and disclosures are not misleading and accurately represent FDIC coverage of the deposits, and (5) provide training for all relevant personnel involved in collecting and placing deposits from third parties and affinity groups. Click here for the guidance.