Enter Search TextSubmitSearch Advanced Search     Home     Deposit Insurance     Consumer Protection     Industry Analysis     Regulations & Examinations     Asset Sales     News & Events     About FDIC

		Home > Regulation & Examinations > Laws & Regulations > FDIC Law, Regulations, Related Acts

FDIC Law, Regulations, Related Acts

[Main Tabs]     [Table of Contents - 4000]     [Index]     [Previous Page]     [Next Page]     [Search] 4000 - Advisory Opinions Pass-Through Deposit Insurance Coverage FDIC--89--41 November 8, 1989 J. William Via, Jr., Counsel   You state in your letter of October 23 that your bank, pursuant to a written agreement with each customer, purchases certificates of deposit as custodian for groups of customers, the certificates being issued in the name *** as Custodian for Virginia Doe, et al., and you indicate that your bank maintains records that reveal the ownership interest of each customer in each deposit. It appears that these deposits qualify for "pass-through" deposit insurance for the benefit of each customer, as you believe is the case. See 12 C.F.R. §§ 330.1(b); 330.2(b).   The regulation of the Comptroller of the Currency entitled "Collective investment", appearing at 12 C.F.R. § 918, and cited by you, applies only to national banks. The trust powers of state chartered banks are based on state law.   We can give no opinion as to how 15 U.S.C. § 77(c)(a)(2) might be construed with respect to the activity of your bank described in your letter. {{4-30-90 p.4420}} [Main Tabs]     [Table of Contents - 4000]     [Index]     [Previous Page]     [Next Page]     [Search]

regs@fdic.gov

Home    Contact Us    Search    Help    SiteMap    Forms Freedom of Information Act (FOIA) Service Center    Website Policies    USA.gov

FDIC Office of Inspector General