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TCH Responds to FDIC’s Request for Comment Related to the Repeal of Reg Q

The Clearing House Association submitted a joint letter with the ABA to the FDIC to suggest that (i) FDIC incorporate the Federal Reserve principles governing earnings credits into a Financial Institution Letter (FIL) to memorialize the Fed rules and govern the continued development of these programs and (ii) Federal Reserve and FDIC host roundtables with the industry to work through certain regulatory details related to the repeal of Regulation Q prior to July 21, 2011. On July 14 the FDIC published in the Federal Register a final rule repealing the prohibition against the payment of interest on demand deposit accounts effective July 21. As requested in TCH’s comment letter, the FDIC has stated that it will continue to rely on the Fed’s interpretation of Reg Q for purposes of determining which accounts are eligible for temporary, unlimited deposit-insurance coverage.