Timeline for financial institution  compliance with RULE 412

Effective Date: June 15, 2010

February 1, 2010 (or earlier)    

*South Carolina Bar Foundation (SCBF) mails information packages and Compliance

Statements to all participating financial institutions

*SCBF is available to answer questions and will begin evaluation of submissions as they

are received

*SCBF posts information for attorneys and bankers on Web site

*SCBF updates lawyers and bankers handbooks

April 1, 2010

*Compliance Statements and materials due back to SCBF

April 12, 2010

*SCBF sends reminder notice to financial institutions that have not submitted

compliance statements.

May 2010            

*SCBF will publish its initial list of eligible financial institutions
 

*SCBF contacts any outstanding financial institutions that have not submitted

compliance statements

May 17, 2010          

*All financial institutions that wish to continue offering IOLTA accounts must have their

forms and any required documentation submitted to SCBF to allow time for evaluation  

May 17, 2010

*SCBF sends reminder notice to financial institutions to implement required operational

and systems changes
 

June 15, 2010

*Financial Institution must have implemented all product and rate changes required for

certification as an eligible institution

June 15, 2010

*SCBF publishes final list of eligible institutions 

*Attorneys may only hold IOLTA funds in financial institutions that have implemented all required changes and have been certified by SCBF to be in compliance with Rule 412