4000 - Advisory Opinions
Use of "Master" Signature Cards for Joint Accounts Where Only One Co-Owner Opens Subsequent Accounts
June 7, 1991
Claude A. Rollin, Counsel
This is in response to your letter, dated May 2, 1991, inquiring about the means by which the FDIC's signature requirement for joint ownership accounts can be satisfied.
In your letter you outline the following fact situation:
At our Association, when we open account #1 for a Customer, we obtain the personal signature of all account owners. However, when secondary accounts are opened by the same combination of owners we use the same card without obtaining new signatures from the owners. Each time a secondary account is opened, the new account number is added to the existing signature card, and the owner who is present in the branch initials in a designated area on the front of the card to activate the POA feature.
You ask whether the FDIC requires new signatures each time a secondary account is opened on an existing signature card. The answer to your question is no because the FDIC's regulations do not require that the opening of an account and the signing of a signature card be contemporaneous.
We have no objection to the use of master signature cards (those which pertain to more than one deposit account), and the subsequent adding of additional accounts, so long as the master signature card clearly indicates how each account is owned and which individuals have the right to withdraw funds from each account.
In my opinion, if a master signature card clearly indicates there are several accounts that are jointly owned by the same combination of individuals and each of those individuals has personally signed the signature card, the accounts will be treated as joint accounts and insured in accordance with our joint account regulation, 12 C.F.R. § 330.7, even if some of those joint accounts were subsequently opened by only one of the co-owners on an existing master signature card and the co-owners did not re-sign the signature card at the time the secondary accounts were opened.