No, we do not believe you need to continue to post the notice. In November 2012, the FDIC urged banks to provide depositors “adequate advance notice in writing” that the temporary unlimited coverage for noninterest-bearing transaction account deposits would expire on December 31, 2012. Notice was not required by a specific law or regulation. The FDIC simply encouraged banks to provide notice “as a matter of prudent commercial practice.” Therefore, we see no reason to continue to post your notice three years after the temporary unlimited coverage expired.

For resources related to our guidance, please see:

• FDIC Financial Institution Letter, FIL-45-2012 — Notice of Expiration: Temporary Unlimited Coverage for Noninterest-Bearing Transaction Accounts (November 5, 2012) (“Although the Dodd-Frank Act imposes no specific notice requirement for IDIs in connection with the expiration of temporary unlimited coverage for NIBTAs, we encourage IDIs, as a matter of prudent commercial practice, to remind their NIBTA depositors about the pending expiration and the impact that expiration will have on their deposit insurance coverage. IDIs may use any reasonable method of providing reminders to depositors, such as individual written notices to each NIBTA depositor or notices on regular account statements. IDIs may use electronic mail for depositors who ordinarily receive account information in this manner.”)

• 12 CFR 330.16(a) (“From December 31, 2010, through December 31, 2012, a depositor's funds in a ‘noninterest-bearing transaction account’ (as defined in § 330.1(s)) are fully insured, irrespective of the SMDIA. Such insurance coverage shall be separate from the coverage provided for other accounts maintained at the same insured depository institution.”)