WASHINGTON (6/22/10)--The Credit Union National Association (CUNA) addressed the Federal Trade Commission’s (FTC) final rule that requires disclosures for financial institutions that do not have federal deposit or share insurance in a recently published final rule analysis. The FTC’s final rule, which will become effective on July 6, requires institutions to inform their members or customers that the institution is not federally backed and that the federal government does not guarantee the depositor will receive money if the institution fails. While a proposal released in 2005 would have required financial institutions to provide this notice to each member or customer in writing, financial institutions may now comply with the rule by posting a disclosure of their insurance situation, in some instances. Those publicly placed disclosures must be visible at each station or window place where deposits are received, at each principal place of business, in all branches where the institution accepts deposits or opens accounts. The disclosures must also be visible on the financial institutions home page. The final rule does not apply to financial institutions that do not receive deposits in amounts less than the maximum insurance level of $250,000. CUNA also addressed recent Federal Reserve Board clarifications to Regulation E, the Electronic Fund Transfer Act, and Regulation DD, the Truth in Savings Act (TISA) in a separate final rule analysis. One item noted by the Fed changes, which were released late last month, was a clarification that institutions may not assess fees for the payment of ATM and one-time debit card overdrafts if consumers do not opt-in to their overdraft programs. The Fed at that time also clarified that Reg DD does not require financial institutions "to exclude from the consumer's balance funds that may be transferred from another account" under retail sweep programs. To read the final rule analyses, use the resource links.