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FDIC Large Bank Deposit Insurance Determination Modernization FAQ
Below is the link to the FAQ published by the FDIC. Number 3 on the list addresses Trust Accounts and the recently enacted FDIC sweep disclosure requirements. This notice reiterates there is no need to send out sweep disclosures to trust department clients.
http://www.fdic.gov/regulations/resources/largebankdim/large_bank_faq_update_2009_06_16.html
The Fiduciary and Investment Risk Management Association, Inc. (FIRMA) is the leading provider of current and relevant fiduciary and investment risk management education and networking opportunities to risk management professionals of banks, trust companies, investment advisors, broker-dealers, insurance companies and other providers of financial services. FIRMA, previously the National Association of Trust Audit and Compliance Professionals (NATACP), has the objective of providing fiduciary risk managers with the tools and knowledge needed to perform their functions in the rapidly changing financial services landscape. Become a Member Today!
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FIRMA is pleased to announce the addition of the interactive “Regulatory Update” to the Web site. The link to this page is called “Regulatory Update,” and is found under the “Member Resources” tab. This link provides an exciting, informative benefit to our members, and is a vital tool in this age of heightened regulation and litigation. Members simply need to subscribe to the resource “provider of preference” from our menu and articles will automatically arrive at your desktop. This tool is updated daily and offers real-time postings of key Regulatory, Compliance, and Risk Management current hot topics. It is designed to give you the valuable, competitive information you need daily without having to search for it. You are invited to visit this site and test its potential firsthand. FIRMA also welcomes feedback and comments.
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Update on Pending Department of Labor Regulations
After the Presidential Inauguration on January 20, 2009, White House Chief of Staff Rahm Emanuel issued a memorandum expressing the new administration's desire to review and approve any pending or recently finalized regulations. The memorandum requested that no new regulations be sent to the Federal Register for publishing, that unpublished regulations be withdrawn from the Federal Register, and that the effective date of regulations published in the Federal Register but not yet effective be postponed for 60 days. This action affected several key regulatory projects relating to ERISA-covered plans that were pending with the U.S. Department of Labor ("DOL"), including proposed new rules requiring disclosure by plan service providers, additional disclosure to participants of participant-directed plans, and new rules and exemptive relief for investment advice services for participants of participant-directed plans and IRA owners. The outlook for these pending rulemaking projects is discussed below.
INDUSTRY NEWS
Total, CNPC Consider Venezuela Oil Block Bids
WSJ.com: US Business 4 July 2009, 3:01 am
CIC Takes Teck Stake
WSJ.com: US Business 4 July 2009, 2:54 am
NY Fed's Chief Backs Preemptive Crisis Moves Fed Should Get Ahead ... - Washington Post
Business - Google News 4 July 2009, 2:41 am
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FX Derivatives Ops Risk QC Analyst
Posted: June 2, 2009
Contact FIRMA to advertise your position.
General Trust Discussion: Pledging Collateral for Trust DDAs Compliance Manager posted on July 1, 2009, 3:02 pm:
The 12 CFR 9.10 reference to "funds awaiting reimvestment or distribution" would include funds that flow through an internal account prior to being posted to an account (dividend, interest, incoming wires, ach, deposits, asset sales, etc.) or being paid out (Trust checks, asset purchases, etc). Many insitituitons also use internal suspense accounts for the movement of funds to/from accounts. If these accounts carry a balance, they would also be univested trust funds that would need to be collateralized.
As for CD's that are purchased from the trustee bank, these are covered under FDIC up to the FDIC limit, however after that, the become uninsured deposits and, at our institution, are considered "self-deposits" in the bank that are included in the calculation for collateral purposes.
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