fdic insurance coverage

FDIC Insurance Coverage

© 4/2021 American Bankers Association


ABA course content is not a substitute for professional legal advice.




Course Introduction Overview Determining Coverage Unique Ownership Scenarios Signage and Advertising Course Conclusion



Course Introduction Overview FDIC Insurance Coverage examines the background and purpose of the FDIC and defines common FDIC terminology. This course explains general rules for insurance coverage and categories, insurance coverage and calculations, and includes FDIC signage and advertising requirements. Version: 4.0 Update: April 2021. No significant changes. ABA course content is not a substitute for professional legal advice. Page 1



Overview Banking is a competitive business, and it is important that banks operate in a safe and sound manner. The Federal Deposit Insurance Corporation (FDIC) is a federal agency organized to insure deposit accounts up to $250,000 at commercial banks and savings associations. This course provides basic information concerning FDIC insurance to enable frontline employees to assist customers and answer customer questions. This course also covers various account types, such as trust accounts, corporate accounts, employee benefit plans, and public unit accounts, but bank employees are encouraged to refer to FDIC resources such as the FDIC website, www.fdic.gov, or to another employee experienced in working with FDIC insurance for additional information. Bank employees may also direct customers to EDIE, the FDIC’s Electronic Deposit Insurance Estimator, also available on the FDIC website. Objectives By the end of FDIC Insurance Coverage, you will be able to

• Describe the purpose and the basics of FDIC insurance • Explain the general rules, coverage, and calculation for FDIC insurance • Describe possible unique ownership scenarios you may face and the insurance coverage for each ownership

category • Explain general information about FDIC signage and advertising

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Overview Introduction The FDIC has many roles, including promoting confidence in the U.S. financial system and limiting the effect on the economy and the financial system when a bank or thrift institution fails. When banks fail, the FDIC works promptly to reimburse insured depositors from the FDIC insurance fund, but it is not meant to slow competition or stop the failure of financial institutions that cannot operate safely and soundly. The FDIC is very specific about the types of accounts that are insured, those that are not insured, and how account coverage is determined based on the ownership rights of the account holders. Objectives By the end of this module, you will be able to

• Explain the background and purpose of the FDIC • Describe the general rules for insurance coverage

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Background and Purpose One of the FDIC's most important functions is to insure the deposit accounts of millions of Americans in all FDIC-insured financial institutions across the country. The FDIC administers the Deposit Insurance Fund (DIF), which insures deposits held in banks and thrift institutions. Look around any lobby of an FDIC insured institution and you will find an official FDIC sign posted at each teller station. The financial institution must display the FDIC signage wherever it normally receives insured deposits. The FDIC performs the following functions:

• Establishes rules for insuring deposits in various accounts • Supervises state chartered banks and thrifts that are not members of the Federal Reserve

Tip: Visit the FDIC website for more information pertaining to the Recordkeeping for Timely Deposit Insurance Determination rule: https://www.fdic.gov/regulations/resources/recordkeeping/ Sidebar: Effective April 1, 2020, the "Recordkeeping for Timely Deposit Insurance Determination" rule requires each insured depository institution that has two million or more deposit accounts (a “covered institution” as defined in the rule) to:

(1) configure its information technology system to be capable of calculating the insured and uninsured amount in each deposit account by ownership right and capacity, which the FDIC would use to make deposit insurance determinations in the event of the institution’s failure, and

(2) maintain complete and accurate information the FDIC needs to determine deposit insurance coverage with respect to each deposit account, except as otherwise provided.

This course does not address this rule in detail as very few U.S. financial institutions are subject to the rule.

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Glossary term: Deposit Insurance Fund (DIF) An insurance fund that guarantees deposits at banks or other savings institutions up to a certain amount. The FDIC maintains the Deposit Insurance Fund through insurance premiums charged to depository institutions. The Deposit Insurance Fund (DIF) is the combined deposit insurance funds from commercial banks and savings and loan associations that guarantee depositors' funds in financial institutions up to $250,000. Page 4



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Background and Purpose Question What role does the FDIC play in today's financial system? Answer The FDIC has many roles, including promoting confidence in the U.S. financial system and limiting the effect on the economy and the financial system when a bank or thrift institution fails. Page 5



FDIC Insurance Basics What are the basic FDIC coverage limits? The FDIC insures deposits according to the ownership category in which the funds are insured and how the accounts are titled. The standard deposit insurance coverage limit is $250,000 per depositor, per FDIC-insured bank, per ownership category. The FDIC separately insures deposits held in different ownership categories, up to at least $250,000, even if held at the same bank. The FDIC can insure revocable trust accounts (including living trusts and informal revocable trusts commonly referred to as payable on death (POD) accounts) with one owner naming three unique beneficiaries up to $750,000. Page 6



FDIC Insurance Basics FDIC insured financial institutions offer a variety of accounts. Some of the accounts are eligible for federal deposit insurance and others are not. > Roll over the terms below to see which accounts are insured and not insured. Insured

• Savings • Time deposits and CDs • Money market, checking, demand deposit • Negotiable Order of Withdrawal (NOW) • Retirement accounts consisting of cash on deposit • Official checks (cashier’s checks, money orders, officer checks, outstanding drafts) • Certified checks, letters of credit, travelers’ checks (Note: there are specific conditions that must be met in order

for these items to be insured) • Prepaid cards (depending on the card program)

Uninsured

• Investments in mutual funds • U.S. Treasury bills, notes, bonds • Annuities • Stocks, bonds, other securities or non-deposit investment products • Contents of safe deposit boxes • Funds lost by the insured institution due to robbery, theft, fraud, embezzlement, or natural disaster

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FDIC Insurance Basics How FDIC coverage works FDIC insurance operates to protect customers in cases of bank mergers/acquisitions and bank failures. Bank mergers/acquisitions When two or more insured banks merge, deposits from the assumed bank are separately insured from deposits at the assuming bank for at least six months after the merger. This grace period gives depositors the opportunity to restructure their accounts, if necessary. There are special rules regarding CDs obtained from the assumed bank. These are separately insured until the earliest maturity date after the end of the six-month grace period. CDs that mature during the six-month period and are renewed for the same term and in the same dollar amount (either with or without accrued interest) continue to be separately insured until the first maturity date after the six-month period. If a CD matures during the six-month grace period and is renewed on any other basis, it would be separately insured only until the end of the six-month grace period. Note In bank failure situations where a depositor already has deposits at the acquiring bank, the six-month grace period described would also apply to these deposits. Page 8



FDIC Insurance Basics What is a bank failure? A bank failure is the closing of a bank by a federal or state banking regulatory agency, generally resulting from a bank's inability to meet its obligations to depositors and others. In the unlikely event of a bank failure, the FDIC acts quickly to ensure depositors get prompt access to their insured deposits. FDIC deposit insurance covers the balance of each depositor's account, dollar-for-dollar, up to the insurance limit, including principal and any accrued interest through the date of the insured bank's closing. When there is no open bank acquirer for the deposits, the FDIC will pay the depositor directly by check up to the insured balance in each account. Such payments usually begin within a few days after the bank closing. Page 9



FDIC Insurance Basics What is FDIC's role in a bank failure? The FDIC acts in two capacities following a bank failure:

• As the “Insurer” of the bank's deposits, the FDIC pays deposit insurance to the depositors up to the insurance

limit • As the “Receiver” of the failed bank, the FDIC assumes the task of collecting and selling the assets of the

failed bank and settling its debts, including claims for deposits in excess of the insured limit Purchase and assumption transaction This is the preferred and most common method, under which a healthy bank assumes the insured deposits of the failed bank. Insured depositors of the failed bank immediately become depositors of the assuming bank and have access to their insured funds. The assuming bank may also purchase loans and other assets of the failed bank. It is important for account owners to note that their deposit contract was with the failed bank and is considered void upon the failure of the bank. The assuming institution has no obligation to maintain either the failed bank rates or terms of the account agreement. Depositors of a failed bank, however, do have the option of either setting up a new account with the acquiring institution or withdrawing some or all of their funds without penalty. Page 10



FDIC Insurance Basics Question In the unlikely event of a bank failure, what is the FDIC’s role? Answer The FDIC acts in two capacities following a bank failure: • As the "Insurer" of the bank's deposits, the FDIC pays deposit insurance to the depositors up to the insurance limit • As the "Receiver" of the failed bank, the FDIC assumes the task of collecting and selling the assets of the failed bank

and settling its debts, including claims for deposits in excess of the insured limit Page 11



Wrap Up In this module you learned the background and purpose of the FDIC. You can define common FDIC terminology and describe what types of accounts are eligible for FDIC insurance coverage. Page 12



Determining Coverage Introduction Calculating FDIC insurance requires a thorough understanding of the different ownership categories and the rules that apply to each category. The rules for each ownership category are different and must be followed carefully for the account to qualify for FDIC insurance coverage. Objectives By the end of this module, you will be able to

• Describe general rules and categories • Describe insurance coverage and calculations

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General Rules and Categories It is sometimes difficult and confusing to try to determine how the FDIC insurance rules and limits apply to a depositor's specific group of deposit accounts—what is insured and what portion (if any) exceeds the coverage limits at that bank. To help resolve situations like this the FDIC created the Electronic Deposit Insurance Estimator, or "EDIE"—an interactive calculator that lets consumers and bankers know, on a per-bank basis, what is or is not covered. EDIE calculates the insurance coverage for personal accounts—deposits held by people in single accounts, joint accounts, Payable on Death/In Trust For (POD/ITF) accounts, living trust accounts, and Individual Retirement Accounts (IRAs). It also calculates the insurance coverage for business accounts—deposits held by corporations, partnerships, and organizations, both for-profit and not-for-profit. In addition to personal and business accounts, EDIE calculates government accounts—deposits held by public units such as school districts, cities, municipalities, counties, and states. EDIE also allows the user to print the reports to save as a personal record. You and your customers can find EDIE on the FDIC's website. https://edie.fdic.gov/ Although you can and should refer customers to EDIE, it is still important to have an overall knowledge of how FDIC insurance works. Page 14

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General Rules and Categories Customer, Mr. Sterling: “I have two accounts. If I put $150,000 in one account and $150,000 in the other account, will all my funds be completely insured?” Suppose you are an employee of Anytown Bank. Richard Sterling, one of your customers, has just inherited $300,000. How would you respond to Richard's question? The FDIC bases insurance coverage on ownership rights to accounts (ownership categories), not simply for each account a customer has with a financial institution. Richard has asked an important question that requires more information about his plans for the money. Every employee of a financial institution should be able to offer some basic information about FDIC insurance coverage. Detailed questions or specific requests for calculating insurance coverage should be referred to more experienced employees who can explain the FDIC rules of ownership to protect customer funds, like Richard’s, against financial institution failure. Page 15



General Rules and Categories Calculating coverage

Basic FDIC deposit insurance coverage limits

Single accounts (owned by one person) $250,000 per owner

Joint accounts (owned by two or more persons)

$250,000 per co-owner

IRAs and certain other retirement accounts $250,000 per owner

Revocable Trust accounts $250,000 per owner per beneficiary up to 5 beneficiaries (more coverage available with 6 or more beneficiaries subject to specific limitations and requirements)

Corporation, Partnership, and Unincorporated Association accounts

$250,000 per corporation, partnership, or unincorporated association

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General Rules and Categories The FDIC insures accounts up to $250,000 per person per ownership category. Accounts must meet the following general rules to qualify for the $250,000 coverage amount:

• The $250,000 limit is calculated by ownership category • Funds held in the same ownership category in the same insured institution are added together

An easy way to remember the basics is that insurance coverage is calculated in the following ways:

• Per person (capacity) • Per ownership rights (category) • Per bank

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General Rules and Categories Misconceptions The following table shows four common misconceptions and the truth about FDIC insurance coverage:

Misconception The truth is… Changing the way an account is “styled” (the order of the account owner’s names) on a signature card will allow another $250,000 of FDIC insurance.

Rearranging the names of the owners, changing the styling of their names, or opening more than one joint account for the same combination of individuals at the same institution does not increase insurance coverage for accounts with joint ownership.

Using multiple social security numbers will increase insurance coverage.

Social security or tax identification numbers do not determine insurance coverage. Using different social security numbers or tax ID numbers on multiple accounts held by the same co-owners will not increase insurance coverage.

Every account is insured up to $250,000. FDIC insurance is aggregated per person, per ownership category, and per separately chartered financial institution.

Accounts opened in different branches of the same financial institution are separately insured.

Accounts opened at all locations of the same financial institution are added together and insured based on ownership category. Accounts opened in separately chartered institutions are insured separately.

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General Rules and Categories The FDIC has some general rules that must be met for an account (including principal and interest) to be covered by deposit insurance. > Click each tab above to learn about the general rules. Page 19



General Rules and Categories Separate institutions Accounts at separately chartered institutions are separately insured, even if the institutions are affiliated. Example If Acme Bank and Safe Bank are separately chartered institutions but the same holding company owns both, their customers' deposit accounts will be separately insured. > Click each tab above to learn about the general rules. Page 19



General Rules and Categories Same institutions Deposits in different branches of the same institution are added together for purposes of deposit insurance. Example Assume Jenny opened an account (as the only account owner) at the Main Street branch of Neverland Bank and opened another checking account (as the only owner) at the downtown branch of Neverland Bank. Because the same institution, Neverland Bank, holds both accounts, these two accounts would be added together when determining FDIC insurance coverage. It is a common misconception of customers that all deposits are covered because the accounts are in different locations. Not all accounts are covered by the FDIC. The accounts that do qualify for insurance coverage in different locations/branches of the same financial institution are added together by ownership categories set by the FDIC. > Click each tab above to learn about the general rules. Page 19



General Rules and Categories Ownership categories It is always important to keep in mind that FDIC insurance coverage is based on the ownership of an account. The FDIC recognizes the following broader list of ownership categories:

• Single ownership • Joint ownership • Revocable trust • Payable on death (POD) • Irrevocable trust • Retirement and other employee benefit plans • Accounts held on behalf of others/Accounts held In Trust For (ITF) • Public unit funds • Corporation • Partnership • Unincorporated association

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General Rules and Categories Exercise Background Tracy comes into your bank office with this question: “I have opened three separate accounts at three of your branches and an investment account at a fourth branch. Does FDIC insure each of my accounts separately?” Instructions Consider Tracy’s question. How would you respond? > Type your answer in the field. When finished, click the Suggested Results button to view possible responses. Suggested Results “Assuming the accounts are in your name only, because they are held at the same bank, even though in different branches, your three deposit accounts will be added together and insured up to $250,000. FDIC insurance, however, only applies to deposit accounts, so your investment account will not be covered by FDIC deposit insurance.” Page 21



Coverage and Calculation Ownership of funds is central to determining insurance of funds on deposit in an FDIC insured institution. Here are two key ownership terms used when discussing FDIC coverage. > Roll over the terms below to see the definitions. Ownership capacity A depositor can be any of the following types:

• A person • A business/organization • A government entity

A depositor does not have to be a citizen or resident of the United States to be eligible for deposit insurance coverage. The general rule applies where shares in all of the deposit accounts he or she owns in the same ownership category, in the same financial institution, are added together. Ownership categories The FDIC has set up different categories of ownership. The following are the most common forms of ownership:

• Single ownership: Only one person owns the account • Joint ownership: Two or more persons own the account • Revocable Trust accounts • Certain retirement accounts

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Coverage and Calculation Calculating coverage Here is how ownership capacity and ownership categories work together. A natural person is a capacity. A joint or sole ownership is a category. Single ownership Joint ownership Account owned by a natural person Accounts held in the names of two or more natural persons.

Individual accounts are established and controlled solely by the person who owns the funds in the account.

Joint accounts qualify (as joint account(s) if all co-owners are in the following situations:

• Are people. Legal entities (corporations, trusts, estates, or partnerships) are not eligible for joint account coverage

• Have equal rights to withdraw deposits from the account. Example, if one co-owner can withdraw deposits on his or her signature alone but the other co-owner can withdraw deposits only with the signature of both co-owners, the co-owners do not have equal withdrawal rights

• Must sign the deposit account signature card unless the account is a CD or is established by an agent, nominee, guardian, custodian, executor or conservator

All funds owned by one person and deposited into single ownership accounts are added together. Example: Katie has three separate accounts and is the only owner of the funds. Balances in all three single ownership accounts are added together

The ownership interests of each co-owner are added together and each owner’s share is insured up to $250,000. Example: Bill and Ted are co-owners on account one. Bill is also a co-owner of account two with Betty. Bill is an equal owner on both joint accounts. Therefore, his ownership portion for these two accounts will be added together and he will be insured for the total that does not exceed $250,000 in the joint ownership category.



and the balance that does not exceed $250,000 will be insured.

Glossary term: Natural person A human being; not a corporation, partnership, and so forth. Page 23



Coverage and Calculation Calculating coverage, continued A corporation or partnership is a capacity. A corporate account is a category. Under FDIC rules, a corporate or business account using one TIN is a separate ownership category and businesses are not able to get additional coverage by using other ownership categories, such as joint accounts. In addition, holding a number of accounts for different purposes will not increase the limits. For example, a corporation with an operating account, a payroll account, and an expense account will still only be insured up to the maximum coverage amount of $250,000 for all three accounts added together. The only exception is when the business is holding funds as a fiduciary (such as for an employee benefit plan), in which case the account is not a business account under FDIC rules, but rather an agency account that provides pass-through insurance to individual plan participants so long as the required record keeping rules are satisfied. Because the FDIC considers a sole proprietorship a single entity with the owner, sole proprietor accounts are not insured separately from the owners. Accounts in the names of sole proprietorships (for example, DBA accounts) are added to the owner's other individual accounts, if any, at the same financial institution and the total is insured up to $250,000. Unlike corporations, sole proprietors can also take advantage of joint accounts to increase their insurance coverage. Page 24



Coverage and Calculation Benny and his wife Carol have been customers of your bank for five years. Benny has three accounts with your bank. The chart below illustrates how these two rules can be applied using Benny's three accounts. Remember that all of Benny's accounts are in the same bank.

Ownership on account Ownership category

Account 1 Benny Single account In this scenario, the balances for accounts 1 and 2 would be added together because they are both in the same ownership category—single ownership—with Benny as the only owner on the account.

Account 2 Benny Single account

Account 3 Benny and Carol Joint account Account 3 would be separately insured because it is a joint account with Carol and, therefore, in a different ownership category.

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Coverage and Calculation Single ownership The chart below takes Benny's example one step further. Because these are both single ownership accounts the amounts in the two accounts are added together for a total of $310,000. Remember the rule for FDIC coverage is $250,000 per owner per account category. Benny is, therefore, insured for $250,000 in the single ownership category. The uninsured amount for Benny in this category is $60,000.

Ownership category Funds in account

Account 1 Single ownership account (Benny is the only owner) $175,000 Account 2 Single ownership account (Benny is the only owner) $135,000 Total of both accounts $310,000 FDIC insured amount $250,000 Amount exceeding the FDIC insurance coverage and therefore uninsured $60,000

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Coverage and Calculation Joint ownership Remember that Benny and Carol had a joint account. Carol also has a joint account with her mother, Ida, and another joint account with her father, Ed. The charts below illustrate how FDIC calculations are used to determine the insurance coverage for Benny, Carol, Ida, and Ed on these joint ownership accounts. This first chart shows the ownership categories and funds/balances in each account.

Ownership category Funds in account Account 3 Joint account (Benny and Carol are the owners) $250,000 Account 4 Joint account (Carol and Ida are the owners) $100,000 Account 5 Joint account (Carol and Ed are the owners) $500,000

Because each of these account owners has equal rights, the amount in each account is divided equally between each owner.

Account 3 Joint account (Benny and Carol are the owners) $250,000

Two owners—Benny and Carol One joint account Funds in account

Account 3 Carol’s share $125,000

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Coverage and Calculation Then each individual's share of the account is added together under this ownership category.

Account 4 Joint account (Carol and Ida are the owners) $100,000 Account 5 Joint account (Carol and Ed are the owners) $500,000

Four owners—Benny, Carol, Ida, Ed

Three joint accounts Funds in account

Account 3 (Benny and Carol) Carol’s share $125,000 Account 4 (Ida and Carol) Carol’s share $50,000 Account 5 (Ed and Carol) Carol’s share $250,000 Total $425,000

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Coverage and Calculation The calculations for these accounts would appear as follows:

Account 3: Benny and Carol divide $250,000 equally

Account 4: Carol and Ida divide $100,000 equally

Account 5: Carol and Ed divide $500,000 equally

Total insured per person

Benny’s ownership amount

$125,000 Benny’s total = Insured: Uninsured:

$125,000 $125,000 $0

Carol’s ownership amount

$125,000 + $50,000 + $250,000 Carol’s total = Insured: Uninsured:

$425,000 $250,000 $175,000

Ida’s ownership amount

$50,000 lda’s total = Insured: Uninsured:

$50,000 $50,000 $0

Ed’s ownership amount

$250,000 Ed’s total = Insured: Uninsured:

$250,000 $250,000 $0

The total insured amount for each individual cannot exceed $250,000 per category. In this example, Carol’s share of all three accounts added together total $425,000—$175,000 over the $250,000 coverage amount. This means Carol has $175,000 of uninsured funds on deposit in this financial institution in the joint ownership category. Page 29



Coverage and Calculation You have seen how coverage applies to Benny, Carol, Ida, and Ed. The chart to the right shows a recap of these accounts. Page 30

Insured Not insured Benny’s ownership

Single accounts $175,000 $135,000 $310,000

$250,000 $60,000

Joint accounts $125,000 $125,000 $0 Total $435,000 $375,000 $60,000 Carol’s ownership Single accounts $0 $0 $0

Joint accounts

$125,000 $50,000 $250,000 $425,000

$250,000 $175,000

Total $425,000 $250,000 $175,000 Ida’s ownership Single accounts $0 $0 $0 Joint accounts $50,000 $50,000 $0 Total $50,000 $50,000 $0 Ed’s ownership Single accounts $0 $0 $0 Joint accounts $250,000 $250,000 $0 Total $250,000 $250,000 $0



Coverage and Calculation Question Ownership capacity is the form in which one or more persons own an account. What are the most common forms of ownership capacity? Answer Natural person, corporation or partnership, fiduciary, or government. Page 31



Coverage and Calculation Exercise Background The date is January 2021, and Ben Warren has two transaction accounts with his bank: A sole owner checking account with a $150,000 balance and a sole owner savings account with a $300,000 balance. Instructions Consider Mr. Warren’s situation. What is the maximum FDIC insurance coverage that he will have in this scenario? > Type your answer in the field. When finished, click the Suggested Results button to view possible responses. Suggested Results Ben will be insured up to $250,000 should the bank fail. Because Ben owns both accounts as a sole owner, the funds are added together to determine coverage. Page 32



Coverage and Calculation Exercise Background The date is January 2021, and Ben Warren has two transaction accounts with his bank: A sole owner checking account with a $250,000 balance and a joint savings account with his son, Cory with a $300,000 balance. Instructions Consider Mr. Warren’s situation. How much FDIC insurance coverage will he be eligible for in this scenario? > Type your answer in the field. When finished, click the Suggested Results button to view possible responses. Suggested Results Ben will be insured up to $400,000 should the bank fail. Because sole ownership and joint ownership are separate categories, Ben is insured for $250,000 in his sole ownership account and an additional $150,000 for his joint ownership account. If Ben was also joint on another account with his wife, however, he would only be insured another $100,000 because any accounts for which he is a joint owner would be added together and any amount over $250,000 would be uninsured. Page 33



Coverage and Calculation Self Check Quiz Which statement reflects the most accurate response to the question, “How is insurance coverage determined?” > Select the correct answer and click Submit.

A) Insurance is determined by ownership capacity and ownership categories B) Each account is insured for up to $250,000 C) The financial institution decides how the $250,000 insurance coverage is determined D) Insurance is determined by an agreement between FDIC and the regulatory agency of each financial institution

A is correct. B is incorrect because FDIC insurance coverage is determined by the rules applied to each ownership category rather than to each account. C is incorrect because the FDIC sets the limits and rules for insurance coveragenot the financial institution. D is incorrect because only the FDIC sets the limits and rules for insurance coverage. Page 34



Coverage and Calculation Self Check Quiz Amy, the CSR at Wholesale Community Bank has two elderly sisters at her desk. They have $1 million dollars in deposits and they want to be sure that all the funds they deposited with Wholesale are insured. How should Amy advise them? > Select the correct answer and click Submit.

A. Sorry, the maximum insurance is $250,000, you must take the remainder to another bank B. Open two joint accounts C. Each of you open a separate single ownership account and open one joint account D. Open two joint accounts, but use a different social security number for each

C is correct. If the sisters each open one sole ownership account, then they will have $250,000 each or a total of $500,000 in insurance. If they also open a joint account, that will provide another $250,000 each, with a total with all accounts of $1,000,000 in coverage. A is incorrect because their accounts can be structured so that they are fully insured. B is incorrect because opening two joint accounts will still only insure them for a total of $500,000 ($250,000 each). D is incorrect because changing the social security number does not increase the coverage and because both accounts are joint, they would still only be insured for $500,000 total. Page 35



Wrap Up The FDIC insurance coverage rules are complicated. How you respond to questions from your customers who may be concerned about insurance coverage is specific to each individual customer. Someone knowledgeable in the area of FDIC insurance coverage should carefully review the answer before responding to the customer. It is common for financial institution employees to tell customers that FDIC insures most accounts up to $250,000, but FDIC insurance coverage is more complicated than that. When customers ask questions, it is best to refer them to a resource that can provide answers to all their individualized, detailed questions. In this module you learned how to describe general rules and categories and FDIC insurance coverage and calculations. Page 36



Unique Ownership Scenarios Introduction You may encounter several unique scenarios as you help your customers establish accounts. Each of the following types of accounts pose distinctive considerations:

• Fiduciary accounts • Payable on Death (POD)/Revocable trust accounts • Government accounts • Health Savings Accounts (HSAs) • Individual Retirement Accounts (IRAs) • Employee retirement fund accounts • Mortgage servicing accounts

Objectives By the end of this module, you will be able to

• Explain the exclusive FDIC insurance aspects of accounts with unique ownership • Identify the requirements for insurance coverage in each ownership category • Explain what happens when an account owner dies

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Fiduciary Accounts What are fiduciary accounts? Fiduciary accounts are deposit accounts owned by one party but held in a fiduciary capacity by another party. Fiduciary relationships may include but are not limited to, an agent, nominee, guardian, executor, or custodian. Common fiduciary accounts include Uniform Transfers to Minors Act (UTMA) accounts, escrow accounts, Interest on Lawyer Trust Accounts (IOLTAs), and deposit accounts obtained through a broker. >Click the Reading button to access and review the required reading, Fiduciary Accounts. Page 38



Fiduciary Accounts True or False Funds deposited by a fiduciary on behalf of a person or entity (the owner) are added to any other deposits the owner holds in the same ownership category at the same bank, but are not insured up to the same applicable limit. Answer: False. This is incorrect because funds deposited by a fiduciary on behalf of a person or entity (the owner) are added to any other deposits the owner holds in the same ownership category at the same bank and are insured up to the applicable limit. Page 39



Revocable Trust Accounts Many customers ask to open an account and wish to name a person or persons to receive the funds in the accounts upon the owner’s death. The ownership category for this type of account, where a party names the beneficiaries, is a revocable trust account. The following two types of revocable trust accounts are insured under the FDIC's coverage rules:

• Informal trust accounts • Formal trust accounts

An informal trust account consists of a signature card on which the owner designates the names of beneficiaries to whom the funds in the account will pass upon the owner's death. Informal revocable trusts are the most common type of revocable trust accounts and generally are referred to in the following names:

• Payable-on-death (POD) • ...in trust for...(ITF) • Totten trusts

The other types of revocable trust accounts are accounts established in connection with formal revocable trusts. Formal revocable trusts are created for estate planning purposes and are referred to as living or family trusts. Coverage for revocable trust accounts is based on the existence of any beneficiary named in the revocable trust, as long as the beneficiary is an individual, a charity, or another nonprofit organization. Page 40



Revocable Trust Accounts For revocable trust account owners with balances of $1.25 million or less in one FDIC insured institution, the maximum coverage will be determined by multiplying the number of different beneficiaries by $250,000. This will apply to the vast majority of revocable trust account owners. Note: For revocable trust deposits that are jointly owned, the $1.25 million threshold would apply to each co-owner's share of all revocable trust deposits at one FDIC-insured bank. For revocable trust accounts where the owner has more than $1.25 million in one FDIC insured institution and has named six or more different beneficiaries in the revocable trust(s), the maximum coverage is the greater of either $1.25 million or the aggregate amount of all the beneficiaries' proportional interests in the revocable trust(s), limited to $250,000 per beneficiary. Page 41



Revocable Trust Accounts In order to be eligible for coverage under this section, and in order for the interest in the account to pass to one or more beneficiaries upon the owner’s death, the account title must state the fact that this is a revocable trust account. For purposes of this requirement, "title" includes the electronic deposit account records of the institution. Page 42



Revocable Trust Accounts Question Johnny Rockman has a revocable trust account in an amount over $1.25 million in National City Bank (an FDIC insured financial institution). Johnny has named six beneficiaries on the revocable trust. What is the maximum FDIC insurance coverage for this trust account and his beneficiaries? Answer For revocable trust accounts where the owner has more than $1.25 million in one FDIC insured institution and has named six or more different beneficiaries in the revocable trust(s), the maximum coverage is the greater of either $1.25 million or the aggregate amount of all the beneficiaries' proportional interests in the revocable trust(s), limited to $250,000 per beneficiary. Page 43



Characteristics of Other Unique Ownership Situations Government Accounts | Health Savings | Individual Retirement | Employee Benefit Plan | Prepaid Cards | Mortgage Servicing You have now learned about the FDIC's coverage rules for fiduciary and revocable trust accounts. At times, you may also handle other types of distinctive ownership when establishing accounts for your customers. >Click each tab to learn about other unique ownership situations and their FDIC insurance coverage. Page 44



Characteristics of Other Unique Ownership Situations Government Accounts A government account includes deposits placed by an official custodian of a government entity, including federal, state, county, municipality, or political subdivision. An official custodian is an appointed or elected official who has control/decision-making authority over funds in the account owned by the public unit. Control of public funds includes possession, as well as the authority to establish accounts for such funds in banks and to make deposits, withdrawals, and disbursements of such funds. Accounts held by an official custodian will be insured as follows:

• In-state accounts–up to $250,000 for the combined amount of all time and savings accounts (including NOW accounts) and–up to $250,000 for all demand deposit accounts (interest-bearing and noninterest-bearing)

• Out-of-state accounts– Up to $250,000 for the combined total of all deposit accounts

By statute, each of the following government entities are eligible for deposit insurance coverage: United States • States • Counties • Municipalities • District of Columbia • Puerto Rico • Other territories • Indian tribes School districts • Power districts • Irrigation districts • Bridge or port authorities • Other “political subdivisions” >Click each tab to learn about other unique ownership situations and their FDIC insurance coverage. Page 44



Characteristics of Other Unique Ownership Situations Health Savings Accounts What is a Health Savings Account? A Health Savings Account (HSA) is an IRS qualified tax-exempt trust or custodial deposit that is established with a qualified HSA trustee, such as an FDIC-insured bank, to pay or reimburse a depositor for certain medical expenses. How does the FDIC insure an HSA? An HSA, like any other deposit, is insured based on who owns the funds and whether beneficiaries have been named. If a depositor opens an HSA and names beneficiaries either in the HSA agreement or in the bank's records, the FDIC would insure the deposit under the Revocable Trust Account ownership category. If a depositor opens an HSA and does not name any beneficiaries, the FDIC would insure the deposit under the single account ownership category. How should an HSA be titled? The identification of a deposit as an HSA, such as "John Smith's HSA," is sufficient for titling the deposit to be eligible for single account or revocable trust account coverage, depending on whether it names eligible beneficiaries. >Click each tab to learn about other unique ownership situations and their FDIC insurance coverage. Page 44



Characteristics of Other Unique Ownership Situations Individual Retirement Accounts The FDIC insurance coverage applies separately to certain retirement accounts. Individual Retirement Accounts (IRAs) fall under a different insurance category than conventional deposit accounts. Deposit accounts—or those offered through a bank or savings and loan association—are all available to be held within a traditional or Roth IRA. These deposit accounts include checking and savings accounts, money market deposit accounts, and certificates of deposit, which FDIC insurance covers. While the FDIC provides coverage to deposit accounts held within a traditional or Roth IRA at an FDIC-insured financial institution, not all IRA accounts fall into this category. IRAs invested in mutual funds, exchange-traded funds (ETFs), individual stocks, bonds, annuities or money market funds, are not FDIC insured. For an individual account, the FDIC provides insurance protection up to $250,000 in addition to the $250,000 coverage for each non-IRA account. >Click each tab to learn about other unique ownership situations and their FDIC insurance coverage. Page 44



Characteristics of Other Unique Ownership Situations Employee Benefit Plan Accounts An employee benefit plan account insured under this category must meet the definition of an employee benefit plan in section 3(3) of the Employee Retirement Income Security Act (ERISA), with the exception of plans that qualify under the Certain Retirement Account ownership category. The FDIC does not insure the plan itself, but insures the deposit accounts owned by the plan. The following are additional requirements for FDIC insurance coverage:

• The investment and management decisions relating to the account must be controlled by a plan administrator (not self-directed by the participant)

• The plan administrator must maintain documentation supporting the plan and the beneficial interest of the participants

• The account must be properly titled as an employee benefit account with the bank When all of these requirements are met, the FDIC will insure each participant's interest in the plan up to $250,000, separately from any accounts the employer or employee may have in the same FDIC insured institution. The FDIC refers to this coverage as "pass-through coverage." Even when plans qualify for pass-through coverage, insurance coverage determination cannot simply be made by multiplying the number of participants by $250,000 because plan participants frequently have different interests in the plan. >Click each tab to learn about other unique ownership situations and their FDIC insurance coverage. Glossary term: Employee benefit plan account An account in which a deposit of a pension plan, defined benefit plan, or other employee benefit plan that is not self-directed is made. Sidebar:



To determine the maximum amount a plan can have on deposit in a single bank and remain fully insured, the plan administrator must first identify the participant who has the largest share of the plan assets, and calculate the participant's share as a percentage of overall plan assets. Then, the plan administrator must divide $250,000 by that percentage to arrive at the maximum fully insured amount that a plan can have on deposit at one bank. Page 44



Characteristics of Other Unique Ownership Situations

Prepaid Cards Funds loaded onto prepaid cards are typically held in pooled (not individual) accounts at banks. Pooled accounts may qualify for FDIC pass-through insurance if they meet certain requirements. Among other things, these funds can be insured when the bank is able to identify the customer in accordance with the bank’s Customer Identification Program (CIP). In addition, the prepaid card must be registered with the card issuer so the FDIC can identify the cardholder should the bank fail. In order for the funds on a prepaid card to be insured, the following requirements must be met:

• The account records at the FDIC-insured bank must disclose that the prepaid card provider is serving as the custodian on behalf of the cardholders

• The records of the FDIC-insured bank, custodian or other party must disclose the identities of the actual owners of the funds and the amount owned by owners

• The deposits must be owned (under the agreements among the parties) by each customer and the other cardholders of the prepaid cards

If these three requirements are met, the funds on the prepaid card will be insured up to $250,000 (per ownership capacity and category) in the same bank.

The prepaid rule also requires prepaid card providers to inform customers pre-purchase whether the money in the account is eligible for pass-through insurance. >Click each tab to learn about other unique ownership situations and their FDIC insurance coverage. Page 44



Characteristics of Other Unique Ownership Situations Mortgage Servicing Accounts How are Mortgage Servicing Accounts insured? Mortgage Servicing Accounts are accounts maintained by a mortgage servicer, in a custodial or other fiduciary capacity, which are composed of payments by mortgagors of principal and interest (P&I). The cumulative balance paid into the account by the mortgagors is insured, with coverage provided to the mortgage servicer or mortgage investor, for up to $250,000 per mortgagor (the borrower). The calculation of coverage for each P&I account is separate if the mortgage servicer or mortgage investor has established multiple P&I accounts in the same bank. For example, a mortgage servicer collects from 1,000 different borrowers their monthly mortgage payments of $2,000 (P&I) and places the funds into a mortgage servicing account. Is the $2,000,000 aggregate balance of the mortgage servicer's mortgage servicing account insured? Yes, the account is fully insured to the mortgage servicer because each mortgagor's payment of $2,000 (P&I) is insured separately for up to $250,000. Although mortgage servicers often collect and escrow tax and insurance (T&I), these accounts are separately maintained and not considered mortgage servicing accounts for deposit insurance purposes. T&I deposits belong to the mortgagors pending payment of their real estate taxes and/ or property insurance premium to the taxing authority or insurance company. The T&I deposits are insured on a "pass-through" basis to each individual mortgagor. >Click each tab to learn about other unique ownership situations and their FDIC insurance coverage. Page 44



Characteristics of Other Unique Ownership Situations Question How does the FDIC insure an HSA? Answer An HSA is insured based on who owns the funds and whether beneficiaries have been named. If a depositor opens an HSA and names beneficiaries either in the HSA agreement or in the bank's records, the FDIC would insure the deposit under the Revocable Trust Account ownership category. If a depositor opens an HSA and does not name any beneficiaries, the FDIC would insure the deposit under the single account ownership category. Page 45



Putting It All Together: Using Multiple Ownership Categories The FDIC provides separate insurance coverage for a depositor's funds at the same insured bank if the deposits are held in different ownership categories. To qualify for this expanded coverage, the requirements for insurance coverage in each ownership category must be met. > Click the Reading button to access and review the required reading, Using Multiple Ownership Categories. Page 46



Putting It All Together: Using Multiple Ownership Categories True or False? The FDIC combines each co-owner's shares of all joint accounts at the bank and insures each co-owner's total up to $250,000. Answer: True. Page 47



Death of Account Owners and Beneficiaries Among the many reasons people put significant sums in FDIC-insured deposits is to keep that money safe—for themselves and for their heirs. The FDIC does not recommend particular financial products or strategies for achieving estate-planning goals. Understanding how deposit insurance works can help customers to make sure their money is fully insured if a bank fails. What happens to insurance coverage after an account owner dies? The FDIC insures a deceased person's accounts as if the person were still alive for six months after the death of the account holder. During this grace period, the insurance coverage of the owner's accounts will not change unless those authorized to do so restructure the accounts. In addition, the FDIC will not apply this grace period if it would result in less coverage. Page 48



Death of Account Owners and Beneficiaries How does the death of a beneficiary of an informal revocable trust (e.g., POD account) affect insurance coverage? There is no grace period if the beneficiary of a POD account dies. In most cases, insurance coverage for the deposits would be reduced immediately. Example A mother deposits $500,000 in a POD account at an insured bank with her two children named as the beneficiaries in the account records of the bank. While the owner and both beneficiaries are alive, the account is insured up to $500,000 ($250,000 times two beneficiaries = $500,000). If one beneficiary dies, insurance coverage for the mother's POD account is immediately reduced to $250,000 ($250,000 times one beneficiary = $250,000). How does the death of a beneficiary of a formal revocable trust affect the insurance coverage? Like informal revocable trusts, the six-month grace period does not apply to the death of a beneficiary named in a formal revocable trust account. However, the terms of the formal revocable trust may provide for a successor beneficiary or some other redistribution of the trust deposits. Depending on these terms, the insurance coverage may or may not change. Page 49



Death of Account Owners and Beneficiaries How does the death of a joint owner affect the insurance coverage? Often, accounts are jointly owned with no beneficiaries listed. In the most common examples, these would be checking accounts, savings accounts or CDs that two or more people own. Typically, there is a "right of survivorship," so, if one of them dies, the survivor(s) will automatically become the sole owner(s) of the funds. Under the insurance rules, each person’s share in all joint accounts with no beneficiaries is protected up to $250,000, separately from other accounts at the same institution. Therefore, if a husband and wife have joint accounts at a bank and there are no beneficiaries named, that money is covered up to $500,000. It is also important to remember that the FDIC defines a joint account as one that is owned by two or more people with no named beneficiaries. Joint accounts are separately insured from accounts that are co-owned but do have beneficiaries, which are considered revocable trust accounts and are insured as described previously. What happens to the insurance coverage of a joint account if one of the owners dies? The FDIC will continue to insure the joint account as if the deceased co-owner were still alive—for up to six months from the date of death. That would mean coverage of up to $500,000 if there were two owners. The FDIC intends that the grace period give the survivor time, if necessary, to ensure that all of the funds are fully insured by restructuring the accounts or moving some funds to another insured bank. Page 50



Death of Account Owners and Beneficiaries Exercise Background Mrs. Robin Banks wants to open a bank money market account for $500,000 and name her grandson Rob and the Humane Society of the United States (HSUS) as POD beneficiaries. In the unlikely event that Mrs. Banks dies and the bank fails, she wants to know if the money will be paid to the HSUS, particularly if Rob dies before she does. Instructions Consider Mrs. Bank’s situation. How would you respond? > Type your answer in the field. When finished, click the Suggested Results button to view possible responses. Suggested Results

Because the HSUS is a 501(c)(3) nonprofit organization, the FDIC beneficiary rules allow Mrs. Banks to name them as POD beneficiary. HSUS should get $250,000 of her money in the unlikely chance that she and Rob die and the bank fails. If she wants them to receive the entire amount of $500,000, she should seek competent legal advice. Page 51



Death of Account Owners and Beneficiaries Question Considering the scenario in the previous exercise, how would you title the account? Answer Robin Banks, Payable on Death to Rob Banks and the HSUS, or Robin Banks, POD Account. Either are OK. Beneficiaries’ names do not have to be in the title. The bank’s records, however, such as the signature card, should clearly show who the POD beneficiaries are. Question What would you tell Mrs. Banks about the insurance coverage? Answer If the bank fails, Mrs. Banks will be insured for the $500,000 in the account—$250,000 for each beneficiary. If she dies and the bank fails, Rob will receive half of the $500,000 (up to the maximum allowable coverage) and the HSUS will receive the other half. Page 52



Wrap Up Because of its complexity, FDIC insurance rules are one of the most commonly misunderstood areas for both bankers and customers. Bankers must be able to identify and understand the key categories of ownership, but should be cautious about advising customers on how to structure their funds to obtain the best overall coverage. In this module, you learned how FDIC calculates insurance coverage across different capacities and categories of ownership. You can also identify some of the unique forms of ownership, and what happens upon the death of an account owner if the bank fails. Page 53



Signage and Advertising Introduction Not all bank employees are directly responsible for the use of FDIC insurance signage at their bank, but frontline employees should be familiar with the requirements. Objectives By the end of this module, you will be able to

• Describe FDIC signage requirements • Explain FDIC advertising requirements

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FDIC Signage Requirements Each insured depository institution must display the official “Member FDIC” sign at each location where insured deposits are usually and normally received—both at the depository institution's principal place of business and in all its branches. The official sign is 7” by 3” in size, with black lettering and gold background, and of the following design:

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FDIC Signage Requirements Although the FDIC signs may be displayed elsewhere in the bank, care should be taken to avoid displaying the sign on desks where an employee may also be licensed to sell non-deposit investment products such as insurance or investments. Banks may also display the sign at an ATM, point of sale terminal, or other remote electronic facility where deposits are received (Remote Service Facilities). If there are any noninsured institutions that share in the Remote Service Facility, any insured depository institution that displays the official sign must clearly show that the sign refers only to a designated insured depository institution(s). This signage must be posted in the bank’s main office, in each branch, and on the bank’s website. Signage is not required at night depositories. The non-English equivalent of the official advertising statement may be used in any advertisement, if the translation has the FDIC’s prior written approval. Ordering and using FDIC signs and logos Banks can order signage directly from the FDIC at no charge. Instead of displaying the official sign, an insured depository institution may display signs that vary from the official sign in size, color, or material at any location where display of the official sign is required or permitted. However, any such varied sign that is displayed in locations where display of the official sign is required must not be smaller in size than the official sign and must have the same color for the text and symbols. Page 56



FDIC Signage Requirements Self Check Quiz Which statement is true regarding FDIC signage? > Select the correct answer and click Submit.

A. A bank must always display FDIC signage on a CSRs desk, even if non-insured products are being discussed

B. The “Member FDIC” logo is required on all night depositories

C. A bank may not display FDIC signage at an ATM, point of sale terminal, or other remote access facility

D. Signage must be posted in the bank’s main office, in each branch, and on the bank’s website D is correct. A is incorrect because care should be taken to remove any FDIC signage when a non-deposit product is discussed or sold. B is incorrect because FDIC signage is not required on night depositories. C is incorrect because a bank may post signs at these facilities. Page 57



Advertising Statement Requirements The FDIC defines "advertising" very broadly as "a commercial message, in any medium, that is designed to attract public attention or patronage to a product or business." Each bank must include the official advertising statement in all advertisements that either promote deposit products and services or promote non-specific banking products and services offered by the institution. An advertisement promotes non-specific banking products and services if it includes the name of the insured depository institution, but does not list or describe particular products or services offered by the institution. An example of such an advertisement would be, "Hometown Community Bank, offering a full range of banking services." The official advertising statement must be, "Member of the Federal Deposit Insurance Corporation." The short title "Member of FDIC" or "Member FDIC," and a reproduction of the symbol of the FDIC may be used by insured depository institutions at their option as the official advertising statement. The official advertising statement must be of sufficient size and print to be clearly legible. When a foreign depository institution has both insured and noninsured U.S. branches, the depository institution must identify which branches are insured and which branches are not in all of its advertisements requiring use of the official advertising statement. Page 58



Advertising Statement Requirements > Click the types of advertisements to see when the use of the official advertising statement is NOT required. Statements and reports of condition When State or Federal law require an insured depository institution to publish its statements of condition and reports of condition. Insured depository institution supplies Insured depository institution supplies such as stationery (except when used for circular letters), envelopes, deposit slips, checks, drafts, signature cards, deposit passbooks, certificates of deposit, etc. Signs or plates Signs or plates in the insured depository institution offices or attached to the building or buildings in which such offices are located. Listings Listings in directories. Blind advertisements Advertisements not setting forth the name of the insured depository institution. Page 59



Advertising Statement Requirements >Click the types of advertisements to see when the use of the official advertising statement is NOT required. Depository institution directory Entries in a depository institution directory, provided the name of the insured depository institution is listed on any page in the directory with a symbol or other descriptive matter indicating it is a member of the Federal Deposit Insurance Corporation. Joint or group advertisements Joint or group advertisements of depository institution services where the names of insured depository institutions and noninsured institutions are listed and form a part of such advertisements. Radio or television Advertisements by radio or television, other than display advertisements, which do not exceed thirty (30) seconds in time. Promotional items Advertisements that are of the type or character that are impractical to include the official advertising statement, including, but not limited to, promotional items such as calendars, pens, pencils, and key chains. Naming FDIC Advertisements which contain a statement to the effect that the depository institution is a member of the Federal Deposit Insurance Corporation, or that the depository institution is insured by the Federal Deposit Insurance Corporation, or that its deposits or depositors are insured by the Federal Deposit Insurance Corporation at least $250,000 for each depositor. Page 60



Advertising Statement Requirements Restrictions when advertising non-deposit products There are restrictions on using the official advertising statement when advertising non-deposit products. In order to ensure that customers are not confused or mislead about what types of products and services are and are not FDIC insured, the FDIC has specific rules relating to the advertising of non-deposit products. The term "non-deposit product" includes, but is not limited to, insurance products, annuities, mutual funds, and securities. For purposes of this definition, a credit product is not a non-deposit product, meaning that using the Member FDIC in an ad for a loan is not required, but is also not prohibited. The term "hybrid product" means a product or service that has both deposit product features and non-deposit product features. A sweep account is an example of a hybrid product. Page 61



Advertising Statement Requirements A bank may not include the official advertising statement or any other statement or symbol which implies or suggests the existence of Federal deposit insurance in any advertisement relating solely to non-deposit products or hybrid products. Sometimes banks wish to advertise that the bank offers both insured and non-insured products, such as on the home page of the bank's website. The FDIC refers to such advertisements as "mixed advertisements" and states that a bank may advertise both insured and non-insured or hybrid products as long as the bank clearly segregates the official advertising statement or any similar statement from that portion of the advertisement that relates to the non-deposit products. Page 62



Advertising Statement Requirements Self Check Quiz New Bank has just opened a branch in a densely populated area that contains a great many businesses. Jordan, the bank's marketing director, wants to create an advertisement that will appeal to the professional population near the branch. He wants to be sure that the advertisement notes that the bank offers not only traditional checking and savings products, but also repo sweep accounts, investments, payroll services, insurance and retirement products. Which statement is true regarding this advertisement? >Select the correct answer and click Submit.

A. The advertisement may not contain the member FDIC logo and statement because it advertises types of non-insured products

B. The advertisement must contain the member FDIC logo and statement because it advertises retirement products C. The advertisement may contain both insured and non-insured products as long as it clearly segregates the

insured products from those that are not insured D. Jordan must create two separate advertisements: one for insured products, and another for those products

offered by the bank that are not insured C is correct. A, B, and D are incorrect because the advertisement may contain both insured and non-insured products as long as the insured products are clearly segregated from those that are not insured. Page 63



Wrap Up In this module you learned some general information about FDIC signage and advertising statement requirements. Page 64



Wrap Up By completing FDIC Insurance Coverage, you can describe the general rules and terminology for insurance coverage. You can also provide a general description of the insurance categories, and describe some general information about FDIC signage and advertising requirements. > Click Exit to close this course. Page 65

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