Answer by Randy Carey: I think that this staff advisory opinion from the FDIC should answer your questions.
Answer by Sonja Kriegsmann: Here is more recent information on this subject from the Code of Federal Regulations (12 CFR 330.1) (or the FDIC's website Law, Regulations, Related Acts - 2000 Rules and Regulations)
330.10 Revocable Trust Accounts.
(b) Required intention and naming of beneficiaries. (1) The required intention in paragraph (a) of this section that upon the owner's death the funds shall belong to one or more beneficiaries must be manifested in the "title" of the account using commonly accepted terms such as, but not limited to, "in trust for," "as trustee for," "payable-on-death to," or any acronym therefore. For purposes of this requirement, "title" includes the electronic deposit account records of the institution. (For example, the FDIC would recognize an account as a revocable trust account even if the title of the account signature card does not designate the account as a revocable trust account as long as the institution's electronic deposit account records identify (through a code or otherwise) the account as a revocable trust account.) The settlor of a revocable trust shall be presumed to own the funds deposited into the account.
330.1 Definitions
(e) Deposit account records means account ledgers, signature cards, certificates of deposit, passbooks, corporate resolutions authorizing accounts in the possession of the insured depository institution and other books and records of the insured depository institution, including records maintained by computer, which relate to the insured depository institution's deposit taking function, but does not mean account statements, deposit slips, items deposited or cancelled checks.
I believe that according to these requirements, your signature card would be sufficient because it would be considered part of the "deposit account records."
Answer by Ken Golliher: If your faith in your tellers is something short of boundless, it might be a good idea to put the acronym in the title just so they are on notice that they need to read the signature card before paying out funds on the death of the original payee.
First published on BankersOnline.com 5/13/13