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Pennsylvania IOLTA Board · Web viewSafe Harbor Rates: A. Pay a “safe harbor” variable interest...

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COMPLIANCE CERTIFICATION FORM Pennsylvania IOLTA Board Rule of Professional Conduct (RPC) 1.15 and Rule of Disciplinary Enforcement (RDE) 221 Verification 1. Declaration of the Financial Institution In order to comply with the requirements of RPC 1.15 regarding comparability, the requirements of RDE 221, and applicable MJ-IOTA regulations, the financial institution shall: (Please check and complete one of the following from A-F below): Safe Harbor Rates: A. Pay a “safe harbor” variable interest rate on all IOLTA and MJ-IOTA accounts with an equivalent yield of not less than the higher of 75% of the Federal Funds Target Rate or 1% thereby becoming a PLATINUM LEADER BANK. B. Pay a “safe harbor” variable interest rate on high balance IOLTA and MJ-IOTA accounts with an equivalent yield equal to the higher of 60% of the Federal Funds Target Rate or 1%, and an equivalent yield equal to the highest non-promotional checking account rate on lower balance IOLTA and MJ-IOTA accounts which is equal to the rate paid on the following account/product:___________________________ at a current rate of:___________%. Alternatively, the safe harbor rate can be paid on all IOLTA and MJ-IOTA accounts. Other Comparable Rates: C. Adjust the interest rate paid on IOLTA and MJ-IOTA accounts to an equivalent yield equal to the rate paid on the following account/product: ___________________________at a current interest rate of: ________%. If a tiered rate, assure the current tiers and rates are provided with the documentation requirements listed below. D. Convert eligible existing IOLTA and MJ-IOTA accounts to a new or existing product type entitled: ____________________________ at a current interest rate equal to: _________%. If a tiered rate, assure the current tiers and rates are provided with the documentation requirements listed below. E. Other (please describe or attach addendum): ___________________________________________________________________________________________________________ ___________________________________________________________________________________________________________ ___________ F. Continue to pay _______% which is the same rate as our _____________________ account which is the highest non-promotional interest rate for which IOLTA and MJ-IOTA accounts qualify. The effective date of the changes above will be: _____________________.
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Page 1: Pennsylvania IOLTA Board · Web viewSafe Harbor Rates: A. Pay a “safe harbor” variable interest rate on all IOLTA and MJ-IOTA accounts with an equivalent yield of not less than

COMPLIANCE CERTIFICATION FORMPennsylvania IOLTA Board

Rule of Professional Conduct (RPC) 1.15 and Rule of Disciplinary Enforcement (RDE) 221 Verification

1. Declaration of the Financial InstitutionIn order to comply with the requirements of RPC 1.15 regarding comparability, the requirements of RDE 221, and applicable MJ-IOTA regulations, the financial institution shall:(Please check and complete one of the following from A-F below):Safe Harbor Rates:□ A. Pay a “safe harbor” variable interest rate on all IOLTA and MJ-IOTA accounts with an equivalent yield of not less than the higher of 75% of the Federal Funds Target Rate or 1% thereby becoming a PLATINUM LEADER BANK.□ B. Pay a “safe harbor” variable interest rate on high balance IOLTA and MJ-IOTA accounts with an equivalent yield equal to the higher of 60% of the Federal Funds Target Rate or 1%, and an equivalent yield equal to the highest non-promotional checking account rate on lower balance IOLTA and MJ-IOTA accounts which is equal to the rate paid on the following account/product:___________________________ at a current rate of:___________%. Alternatively, the safe harbor rate can be paid on all IOLTA and MJ-IOTA accounts.Other Comparable Rates:□ C. Adjust the interest rate paid on IOLTA and MJ-IOTA accounts to an equivalent yield equal to the rate paid on the following account/product: ___________________________at a current interest rate of: ________%. If a tiered rate, assure the current tiers and rates are provided with the documentation requirements listed below.□ D. Convert eligible existing IOLTA and MJ-IOTA accounts to a new or existing product type entitled: ____________________________ at a current interest rate equal to: _________%. If a tiered rate, assure the current tiers and rates are provided with the documentation requirements listed below.□ E. Other (please describe or attach addendum): _________________________________________________________________________________________________________________________________________________________________________________________________________________________________□ F. Continue to pay _______% which is the same rate as our _____________________ account which is the highest non-promotional interest rate for which IOLTA and MJ-IOTA accounts qualify.The effective date of the changes above will be: _____________________.

Page 2: Pennsylvania IOLTA Board · Web viewSafe Harbor Rates: A. Pay a “safe harbor” variable interest rate on all IOLTA and MJ-IOTA accounts with an equivalent yield of not less than

2. Documentation Requirement. No documentation is required if the safe harbor rate is paid on ALL IOLTA and MJ-IOTA accounts. If the safe harbor rate is not paid on ALL IOLTA and MJ-IOTA accounts, please attach substantiating documentation for all bank deposit/investment products noted below:Internal rate sheet on ALL deposit/investment accounts.Explanatory product literature and disclosures in support of Part 1 above.Any analysis or explanation in support of Part 1 above.All documentation and disclosures for business sweep products.Please Note: Submission is incomplete without the above documentation and may delay approval as an Eligible Institution to offer attorney Trust Accounts, including IOLTA Accounts.

3. Certification.Name of Financial Institution_______________________________________________Address_____________________________________________________________________________________________________________________________________Name of person executing this certification______________________________________Title____________________________________________________________________Contact person if different from above________________________________________Telephone__________________________Email_______________________________Fax _______________________________Web Address________________________I certify that the financial institution wishes to be approved as an Eligible Institution which may offer attorney Trust Accounts, including IOLTA accounts. I certify that the account product and/or rate(s) declared above are the highest non-promotional rates generally offered to other customers and will be paid on all IOLTA and MJ-IOTA accounts. I certify that if account products and/or rates offered by the financial institution change and the account product and/or rate(s) declared above no longer satisfy applicable comparability requirements, the financial institution will file a new Compliance Certification Form and will pay rates on IOLTA and MJ-IOTA accounts which do satisfy applicable comparability requirements. I certify the above statements are true and accurate and that the information in sections 1 and 2 has been provided.Signature _____________________________________________________________Date _____________________________Please mail or fax this form to:Pennsylvania IOLTA BoardP O Box 62445Harrisburg, PA 17106-2445Fax: 717-238-2003Telephone: 717-238-2001


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