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For purposes of the sweep in 370.4(c), does a noninterest-bearing savings deposit also include a noninterest-bearing money market deposit account (MMDA)?

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Yes. The term “savings deposit” includes an MMDA. Therefore, a “noninterest-bearing savings deposit account” includes a noninterest-bearing MMDA. What if the funds in a guaranteed low-interest NOW account (with interest rate no higher than 0.50 percent through June 30, 2010 (or December 31, 2009 for those institutions that opt out of the extension)) are swept or transferred into (or reclassified as) a low-interest savings deposit account (with interest rate no higher than 0.50 percent through June 30, 2010 (or December 31, 2009 for those institutions that opt out of the extension)? Will the funds lose the benefit of the guarantee? The FDICs regulations include the following rule: [I]n the case of funds swept from a noninterest-bearing transaction account to a noninterest-bearing savings deposit account, the FDIC will treat the swept funds as being in a noninterest-bearing transaction account. This rule is based upon the premise that the sweep or reclassification of the funds for reserv

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Yes. The term “savings deposit” includes an MMDA. Therefore, a “noninterest-bearing savings deposit account” includes a noninterest-bearing MMDA. What if the funds in a guaranteed low-interest NOW account (with interest rate no higher than 0.50 percent through June 30, 2010 and 0.25 percent after June 30, 2010 ) are swept or transferred into (or reclassified as) a low-interest savings deposit account (with interest rate no higher than 0.50 percent through June 30, 2010 and 0.25 percent after June 30, 2010 )? Will the funds lose the benefit of the guarantee? The FDIC’s regulations include the following rule: “[I]n the case of funds swept from a noninterest-bearing transaction account to a noninterest-bearing savings deposit account, the FDIC will treat the swept funds as being in a noninterest-bearing transaction account.” This rule is based upon the premise that the sweep or reclassification of the funds for reserve purposes does not change the basic nature of the funds for other purpo

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