Executive Summary
- This page is a customer-continuity guide for a failed-bank assumption transaction, not a generic recap of an FDIC press release.
- On January 17, 2025, Pulaski Savings Bank was closed, the FDIC was appointed receiver, and Millennium Bank assumed all deposits. For most customers, the immediate question was not policy theory. It was what to do with payroll, loan payments, checks, ACH activity, escrow, and records.
- The practical legal value in a transaction like this is distinguishing what now runs through the assuming bank, what still involves the FDIC as receiver, and what a customer should document immediately to reduce operational or fraud risk.
What Happened on January 17, 2025
According to the FDIC’s January 17, 2025 press release, the Illinois regulator closed Pulaski Savings Bank, appointed the FDIC as receiver, and Millennium Bank of Des Plaines, Illinois assumed all deposits of Pulaski Savings Bank. The FDIC also published customer FAQs explaining what depositors and borrowers should expect immediately after the closing.
For customers, an assumption transaction is first and foremost a continuity event. The legal issue is not just whether deposits remain insured. It is whether payments clear, whether loan servicing instructions change, whether autopays and direct deposits continue, who issues year-end tax forms, and when a separate receiver claim process becomes necessary. That is why a narrowly practical guide is more useful here than another high-level article about bank stability.
What “Assumes All Deposits” Means in Practice
When an assuming bank takes all deposits, ordinary deposit customers usually transition into the assuming institution’s system instead of standing in line for a separate insurance payout. That tends to reduce disruption, but it does not eliminate the need for follow-up. Businesses should still verify online-access changes, account naming, signer access, ACH continuity, wire templates, and fraud-monitoring settings. Consumers should confirm debit-card activity, direct deposit timing, online banking access, and whether any automatic bill-pay relationships need attention.
The FDIC’s Pulaski FAQs also make clear that some issues still require separate attention. For example, customers with Pulaski deposits held through a broker were instructed to contact their broker with questions. That is a good example of why customers should avoid assuming every relationship is handled identically just because the assuming bank took all deposits.
First 48-Hour Continuity Checklist for Customers
1. Confirm access before you wait for a problem
Do not assume that because deposits were assumed, every channel is operating exactly as it did before. Log in, verify balances, check whether mobile access works, and review any notices from Millennium Bank or the FDIC. Businesses should also confirm treasury-management functions, positive pay settings, lockbox or remote-deposit features, and internal user permissions.
2. Review automatic money movement
Identify payroll files, vendor ACH pulls, mortgage drafts, rent autopays, merchant-processing sweeps, and recurring transfers tied to the closed bank. The fastest way to turn a manageable transition into a costly one is to discover a failed draft or duplicate transfer after the fact. A same-day review of scheduled items is worth the time.
3. Preserve transition records
Download or save account statements, notices, screenshots, payment confirmations, and any communications from the old and new institution. This is especially important for businesses, estates, and trust or escrow relationships. If a dispute later arises over timing, access, or payment history, the record you preserved during the first week will matter more than memory.
Loan, Escrow, and Payment Issues
The FDIC’s FAQs for Pulaski customers provide several points that borrowers should treat as operational instructions. The agency said borrowers should continue making payments according to their written contracts and could continue sending payments to the same address with checks payable to Pulaski Savings Bank unless they received different instructions. The FAQs also said services previously performed in connection with a loan would continue, including escrow-related functions, and that customers should notify their loan officer immediately if they received notice that taxes or insurance had not been paid.
That guidance leads to a simple rule: keep paying, but document everything. If you mail or electronically transmit a payment during a transition period, save proof. If you have a loan modification in process, construction disbursement questions, escrow concerns, or payoff timing needs, communicate in writing and keep copies. Customers often create avoidable problems by stopping payment activity until the situation “settles down.” In most transactions, that is the wrong move unless a written notice specifically says otherwise.
Tax Forms, Claims, and Other Receiver Issues
The Pulaski FAQ page also addressed year-end reporting and claims issues. Millennium Bank was identified as responsible for mailing 1099 tax information for deposit accounts, while 1098 reporting for loans would be handled by the FDIC or the loan servicer, with borrowers to be notified of servicing changes. That split matters because customers often assume one institution will handle every tax document after a failure event.
The FAQs further noted that if Pulaski Savings Bank owed money to a creditor, the creditor had to submit a claim through the FDIC’s failed-bank claims process. That is different from ordinary depositor continuity. If you are not simply a depositor or borrower but instead believe the failed institution owes you money under a different relationship, you may be in receiver-claim territory and should treat deadlines and proof requirements carefully.
Special Issues for Business Customers
Business customers typically have more operational exposure than consumer depositors during an assumption transaction. Payroll files may need revalidation. AP and AR teams may need to notify counterparties. Fraud controls may need to be reset. Lockbox, merchant, and wire procedures may need to be confirmed. Signatory lists, board resolutions, or entity-authority records may also need refreshing depending on the new bank’s onboarding steps.
For that reason, a commercial customer should run a short internal transition meeting covering cash position, scheduled payments, wire permissions, fraud controls, lender communications, and customer-facing notices. The goal is to reduce the chance that a purely operational gap later looks like a legal dispute or losses event.
How This Page Stays Different From Other Pulaski/Millennium Coverage
There are several pages in this content cluster about the Pulaski closing and Millennium assumption. This page is intentionally narrower. Its job is to answer the customer-continuity questions that arise after the assumption is announced: what to verify, what to keep paying, what records to save, and which issues still belong with the FDIC as receiver. That customer-side angle helps this page stay useful without repeating broader institution-side commentary.
Practical Action Checklist
- Verify account access, balances, and user permissions immediately.
- Review all automatic deposits, drafts, payroll files, and ACH activity tied to the closed bank.
- Continue loan payments according to contract terms unless written instructions change that process.
- Preserve notices, statements, payment confirmations, and screenshots during the transition window.
- Separate deposit questions, loan-servicing questions, brokered-deposit questions, and creditor-claim questions so the issue goes to the right party.
- For business accounts, run a same-day treasury, AP, payroll, and fraud-controls review.
Related Legal Resources
- FIL-01: Millennium Bank Assumes Pulaski Deposits
- FIL-23 Regulatory Role in Pulaski Bank Closure
- FIL-28: Pulaski Savings Bank Closure & Deposit Assumption
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Frequently Asked Questions
Do I stop making loan payments after a failed-bank assumption transaction?
Usually no. In the Pulaski FAQs, the FDIC said borrowers should continue making payments according to their written contracts unless and until they receive different instructions.
Who handles brokered deposits after a transaction like this?
The FDIC’s Pulaski FAQ said customers with deposits through a broker should contact that broker with questions, which is a reminder that not every relationship is handled the same way as a direct depositor account.
When does a customer need to think about the FDIC claims process instead of ordinary account continuity?
When the issue is not ordinary deposit or loan servicing but a separate claim that the failed bank owed money under another relationship, because that may require a formal receiver claim with proof and deadlines.
