Just in case you didn’t have a chance to read The NCUA Report for December last week or it’s still on your to-do list let me take this opportunity to bring one pressing item to your attention. Hidden at the bottom of page 7, is NCUA’s official notification to credit unions offering non-interest bearing accounts. NCUA’s notice indicates that the unlimited coverage ends December 31st (barring an Act of Congress) and that credit unions are expected to take reasonable steps to notify their members of this change.
Well, if you are thinking what I am thinking, a little more advanced notice would have been nice, perhaps an NCUA Letter to Credit Unions. Looking at the calendar your credit union probably already had to deliver the statement insert information to the processor for December. So what should you do? Well, no worries, NCUA plans to post additional information on the topic. (Yes, that is supposed to be humorous) For those of you who may not want to wait for NCUA guidance, you should check out the FAQ the FDIC released on this very topic in early November. Now remember, this is from the FDIC so you can’t take the sample notification language and just copy and paste, but it’s definitely a starting point in the pursuit of taking reasonable steps to notify your members.
Finally, let me point out that the Dodd-Frank Act did not impose any specific notice requirements in connection with the expiration of the temporary insurance. This is strictly a friendly recommendation from the Regulator.