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Nutter Bank Report, Special Edition: Temporary Liquidity Guarantee Program’s Opt-Out Date Is Dec. 5

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| Legal Update

The FDIC on November 21 adopted a final rule implementing the Temporary Liquidity Guarantee Program (TLG Program), which guarantees newly issued senior unsecured debt of banks, thrifts and most bank and thrift holding companies (the Debt Guarantee Program), and provides full deposit insurance coverage of non-interest bearing transaction accounts regardless of dollar amount (the Transaction Account Guarantee Program). By December 5, all eligible institutions must take action with respect to both the Transaction Account Guarantee Program and the Debt Guarantee Program. All institutions must complete an election form to either opt-out of one or both components of the TLG Program or provide data to the FDIC to determine each participating institution’s debt guarantee limit and agree to certain terms. The TLG Program election form is available via FDICconnect.  Institutions that remain in either program must comply with various disclosure requirements that become effective on Dec. 19. Before that date, the rule states that eligible institutions “should provide adequate disclosures” in a “commercially reasonable manner.” More information is available at and

Nutter Bank Report

Nutter Bank Report is a monthly electronic publication of the Banking and Financial Services Group of the law firm of Nutter McClennen & Fish LLP. Chambers and Partners, the international law firm rating service, has ranked Nutter’s Banking and Financial Services practice among the top banking practices in the nation in the 2007 Chambers and Partners U.S. rankings. The “well known and well-versed” Nutter team “excels” at corporate and regulatory banking advice, according to the 2007 Chambers Guide. Visit the 2007 U.S. rankings at  The Nutter Bank Report is edited by Matthew D. Hanaghan. Assistance in the preparation of this issue was provided by Lisa M. Jentzen.  The information in this publication is not legal advice. For further information, contact:

Gene A. Blumenreich
Tel: (617) 439-2889

Kenneth F. Ehrlich
Tel: (617) 439-2989

Michael K. Krebs
Tel: (617) 439-2288

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