Notice2024-17298
Request for Information on Deposits
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
August 6, 2024
Issuing agencies
Federal Deposit Insurance Corporation
Abstract
The Federal Deposit Insurance Corporation (FDIC) is soliciting comments from interested parties on deposit data that is not currently reported in the Federal Financial Institutions Examination Council's (FFIEC) Consolidated Reports of Condition and Income (Call Report) or other regulatory reports, including for uninsured deposits. The FDIC seeks information on the characteristics that affect the stability and franchise value of different types of deposits and whether more detailed or more frequent reporting on these characteristics or types of deposits could enhance offsite risk and liquidity monitoring, inform analysis of the benefits and costs associated with additional deposit insurance coverage for certain types of deposits, improve risk sensitivity in deposit insurance pricing, and provide analysts and the general public with accurate and transparent data.
Full Text
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<title>Federal Register, Volume 89 Issue 151 (Tuesday, August 6, 2024)</title>
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[Federal Register Volume 89, Number 151 (Tuesday, August 6, 2024)]
[Notices]
[Pages 63946-63953]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2024-17298]
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FEDERAL DEPOSIT INSURANCE CORPORATION
RIN 3064-ZA42
Request for Information on Deposits
AGENCY: Federal Deposit Insurance Corporation.
ACTION: Request for information and comment.
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SUMMARY: The Federal Deposit Insurance Corporation (FDIC) is soliciting
comments from interested parties on deposit data that is not currently
reported in the Federal Financial Institutions Examination Council's
(FFIEC) Consolidated Reports of Condition and Income (Call Report) or
other regulatory reports, including for uninsured deposits. The FDIC
seeks information on the characteristics that affect the stability and
franchise value of different types of deposits and whether more
detailed or more frequent reporting on these characteristics or types
of deposits could enhance offsite risk and liquidity monitoring, inform
analysis of the benefits and costs associated with additional deposit
insurance coverage for certain types of deposits, improve risk
sensitivity in deposit insurance pricing, and provide analysts and the
general public with accurate and transparent data.
DATES: Comments must be received on or before October 7, 2024.
ADDRESSES: Interested parties are invited to submit written comments,
identified by RIN 3064-ZA42, by any of the following methods:
<bullet> Agency Website: <a href="https://www.fdic.gov/resources/regulations/federal-register-publications/">https://www.fdic.gov/resources/regulations/federal-register-publications/</a>. Follow the instructions for
submitting comments on the agency website.
<bullet> Email: <a href="/cdn-cgi/l/email-protection#13707c7e7e767d67605375777a703d747c65"><span class="__cf_email__" data-cfemail="2645494b4b434852556640424f4508414950">[email protected]</span></a>. Include RIN 3064-ZA42 in the
subject line of the message.
<bullet> Mail: James P. Sheesley, Assistant Executive Secretary,
Attention: Comments--RIN 3064-ZA42, Federal Deposit Insurance
Corporation, 550 17th Street NW, Washington, DC 20429.
<bullet> Hand Delivery: Comments may be hand delivered to the guard
station at the rear of the 550 17th Street NW building (located on F
Street NW) on business days between 7:00 a.m. and 5:00 p.m.
<bullet> Public Inspection: Comments received, including any
personal information provided, may be posted without change to <a href="https://www.fdic.gov/resources/regulations/federal-register-publications/">https://www.fdic.gov/resources/regulations/federal-register-publications/</a>.
Commenters should submit only information that the commenter wishes to
make available publicly. The FDIC may review, redact, or refrain from
posting all or any portion of any comment that it may deem to be
inappropriate for publication, such as irrelevant or obscene material.
The FDIC may post only a single representative example of identical or
substantially identical comments, and in such cases will generally
identify the number of identical or substantially identical comments
represented by the posted example. All comments that have been
redacted, as well as those that have not been posted, that contain
comments on the merits of this document will be retained in the public
comment file and will be considered as required under all applicable
laws. All comments may be accessible under the Freedom of Information
Act.
FOR FURTHER INFORMATION CONTACT: Division of Insurance and Research:
Ashley Mihalik, Associate Director, Financial Risk Management, 202-898-
3793, <a href="/cdn-cgi/l/email-protection#c8a9a5a1a0a9a4a1a388aeaca1abe6afa7be"><span class="__cf_email__" data-cfemail="6e0f0307060f0207052e080a070d40090118">[email protected]</span></a>; Kayla Shoemaker, Chief, Banking and Regulatory
Policy, 202-898-6962, <a href="/cdn-cgi/l/email-protection#95fef4e6fdfaf0f8f4fef0e7d5f3f1fcf6bbf2fae3"><span class="__cf_email__" data-cfemail="d7bcb6a4bfb8b2bab6bcb2a597b1b3beb4f9b0b8a1">[email protected]</span></a>; Legal Division: Sheikha
Kapoor, Assistant General Counsel, 202-898-3960, <a href="/cdn-cgi/l/email-protection#98ebf3f9e8f7f7ead8fefcf1fbb6fff7ee"><span class="__cf_email__" data-cfemail="94e7fff5e4fbfbe6d4f2f0fdf7baf3fbe2">[email protected]</span></a>;
Vivek Khare, Senior Counsel, 202-898-6847; or Ryan McCarthy, Counsel,
202-898-7301, <a href="/cdn-cgi/l/email-protection#e2909b8f81818390968a9ba284868b81cc858d94"><span class="__cf_email__" data-cfemail="a4d6ddc9c7c7c5d6d0ccdde4c2c0cdc78ac3cbd2">[email protected]</span></a>.
SUPPLEMENTARY INFORMATION:
I. Policy Objectives
The bank failures that occurred in March 2023 and subsequent events
renewed focus by financial regulatory agencies, banks, investors, and
the public on deposit insurance coverage, bank funding concentrations,
and certain banks' reliance on uninsured deposits. While banks are
required to provide certain data on deposit liabilities on the Call
Report,\1\ they do
[[Page 63947]]
not report comprehensive data on the composition of insured and
uninsured deposits.\2\ Through this request for information, the FDIC
is seeking to further evaluate whether and to what extent certain types
of deposits may behave differently from each other, particularly during
periods of economic or financial stress.
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\1\ The ``Call Report'' consists of the Consolidated Reports of
Condition and Income for a Bank with Domestic and Foreign Offices
(FFIEC 031), the Consolidated Reports of Condition and Income for a
Bank with Domestic Offices Only (FFIEC 041), and the Consolidated
Reports of Condition and Income for a Bank with Domestic Offices
Only and Total Assets Less than $5 Billion (FFIEC 051). U.S.
branches and agencies of foreign banks file the Report of Assets and
Liabilities of U.S. Branches and Agencies of Foreign Banks (FFIEC
002). FFIEC 002 filers report many of the same deposit liabilities
items as Call Report filers, including estimated uninsured deposits,
preferred deposits, transaction accounts, and nontransaction
accounts.
\2\ The appendix to this document details relevant information
on deposit liabilities available from the Call Report and other
regulatory reports.
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Specifically, the FDIC is soliciting comments on deposit data that
is not currently reported in the Call Report or other regulatory
reports, including for uninsured deposits, to gather information on the
characteristics that affect the stability and franchise value of
different types of deposits and whether more detailed or more frequent
reporting on these characteristics or types of deposits could enhance
offsite risk and liquidity monitoring; inform analysis of the benefits
and costs associated with additional deposit insurance coverage for
certain types of deposits; improve risk sensitivity in deposit
insurance pricing; and provide analysts and the general public with
accurate and transparent data.
II. Background Information
A. The Events of March 2023 and the Role of Deposit Information in
Offsite Risk and Liquidity Monitoring
In March 2023, runs of uninsured deposits contributed to the
failures of Silicon Valley Bank and Signature Bank, respectively the
second and third largest bank failures in the FDIC's history at the
time, and the subsequent failure of First Republic Bank on May 1, 2023.
These runs were exacerbated by each bank's high reliance on uninsured
deposit funding and concentrations in the depositor base, among other
factors.\3\ The failures of these institutions and subsequent events
prompted a renewed focus by regulators, banks, investors, and the
public on deposit insurance, funding concentrations, and reliance on
uninsured deposits.
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\3\ See Material Loss Review of Silicon Valley Bank, Office of
the Inspector General of the Board of Governors of the Federal
Reserve System and the Consumer Financial Protection Bureau, 2023-
SR-B-013, September 25, 2023. Available at: <a href="https://oig.federalreserve.gov/reports/board-material-loss-review-silicon-valley-bank-sep2023.pdf">https://oig.federalreserve.gov/reports/board-material-loss-review-silicon-valley-bank-sep2023.pdf</a>. See also Material Loss Review of Signature
Bank of New York, Office of the Inspector General of the Federal
Deposit Insurance Corporation, EVAL-24-02, October 2023. Available
at: <a href="https://www.fdicoig.gov/sites/default/files/reports/2023-12/EVAL-24-02.pdf">https://www.fdicoig.gov/sites/default/files/reports/2023-12/EVAL-24-02.pdf</a>. See also Material Loss Review of First Republic
Bank, Office of the Inspector General of the Federal Deposit
Insurance Corporation, EVAL-24-03, November 2023. Available at:
<a href="https://www.fdicoig.gov/sites/default/files/reports/2023-12/EVAL-24-03.pdf">https://www.fdicoig.gov/sites/default/files/reports/2023-12/EVAL-24-03.pdf</a>.
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A bank's liability structure can reflect its risk-taking behavior,
and information about an institution's funding base is important in
evaluating liquidity risk and interest rate risk. As demonstrated
during the spring 2023 bank failures, deposit data are also important
for monitoring liquidity. The experience in spring 2023 demonstrated
that depositors may be able to move funds extremely quickly in the
event of a bank's deteriorating condition or negative media attention.
Silicon Valley Bank had an extremely high level of uninsured
deposits and the bank's management and board of directors overestimated
the stability of the deposit base.\4\ The deposit withdrawals happened
quickly after clients began to speculate about the bank's solvency on
various social media platforms.\5\ This demonstrates that the ubiquity
of new technologies, such as social media and mobile banking, may mean
that potential future bank runs and potential contagion effects happen
at an accelerated pace.
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\4\ See Material Loss Review of Silicon Valley Bank, Office of
the Inspector General of the Board of Governors of the Federal
Reserve System and the Consumer Financial Protection Bureau, 2023-
SR-B-013, September 25, 2023. Available at: <a href="https://oig.federalreserve.gov/reports/board-material-loss-review-silicon-valley-bank-sep2023.pdf">https://oig.federalreserve.gov/reports/board-material-loss-review-silicon-valley-bank-sep2023.pdf</a>.
\5\ Ibid. Another account of the events is that the genesis of
the run on Silicon Valley Bank was private communications among a
networked group of sophisticated investors. See, e.g., Financial
Times, ``Y2K23's Y2K Moment: Blaming the internet for Bank Runs,''
February 5, 2024. Available at: <a href="https://www.ft.com/content/74a7ec7c-cd7e-4e69-8af0-21dead706855">https://www.ft.com/content/74a7ec7c-cd7e-4e69-8af0-21dead706855</a>.
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Deposit data are also important for receivership purposes, as the
presence of deposit insurance coverage has direct implications for the
costs associated with the resolution of a failed institution. The FDIC
has issued regulations applicable to certain large banks to facilitate
its ability to make timely deposit insurance determinations in the
event of failure.\6\ Providing insured depositors access to their funds
may require the completion of an insurance determination, which
involves the FDIC obtaining and analyzing depositor and account data to
determine deposit account ownership type and the appropriate insurance
status.
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\6\ See 12 CFR 360.9 (Large-Bank Deposit Insurance Determination
Modernization) and 12 CFR part 370 (Recordkeeping for Timely Deposit
Insurance Determination).
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The Material Loss Reviews conducted following the failures of
Silicon Valley Bank, Signature Bank, and First Republic Bank provide
support for enhanced monitoring of uninsured deposit levels and
concentrations. The recommendations resulting from the Material Loss
Reviews include monitoring and evaluation of rapid growth and
concentrations, including growth and concentrations of uninsured
deposits, in total, and from specific depositors or depositors in
specific industries.\7\ The Material Loss Reviews for Signature Bank
and First Republic Bank specifically recommend an evaluation of whether
updates to examination guidance are needed in the areas of stability of
deposits, including large and long-term uninsured depositor
relationships, and the velocity and magnitude of potential deposit
outflows, including the supervision of liquidity stress testing. In
addition, in the FDIC's Supervision of First Republic Bank report, the
FDIC's Chief Risk Officer identified as a matter for further study, the
need for enhanced examination guidance related to supervising banks
that are overly reliant on uninsured deposit funding or have
concentrations in uninsured deposits.\8\
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\7\ See Material Loss Review of Silicon Valley Bank, Office of
the Inspector General of the Board of Governors of the Federal
Reserve System and the Consumer Financial Protection Bureau, 2023-
SR-B-013, September 25, 2023. Available at: <a href="https://oig.federalreserve.gov/reports/board-material-loss-review-silicon-valley-bank-sep2023.pdf">https://oig.federalreserve.gov/reports/board-material-loss-review-silicon-valley-bank-sep2023.pdf</a>. See also Material Loss Review of Signature
Bank of New York, Office of the Inspector General of the Federal
Deposit Insurance Corporation, EVAL-24-02, October 2023. Available
at: <a href="https://www.fdicoig.gov/sites/default/files/reports/2023-12/EVAL-24-02.pdf">https://www.fdicoig.gov/sites/default/files/reports/2023-12/EVAL-24-02.pdf</a>. See also Material Loss Review of First Republic
Bank, Office of the Inspector General of the Federal Deposit
Insurance Corporation, EVAL-24-03, November 2023. Available at:
<a href="https://www.fdicoig.gov/sites/default/files/reports/2023-12/EVAL-24-03.pdf">https://www.fdicoig.gov/sites/default/files/reports/2023-12/EVAL-24-03.pdf</a>.
\8\ See FDIC's Supervision of First Republic Bank, FDIC,
September 8, 2023. Available at: <a href="https://www.fdic.gov/news/press-releases/2023/pr23073a.pdf">https://www.fdic.gov/news/press-releases/2023/pr23073a.pdf</a>.
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Furthermore, the 2023 Annual Report of the Financial Stability
Oversight Council (FSOC) noted that reviews of recent events yield
lessons about the ways in which banking supervision and resolution
preparedness could be enhanced, and suggested that more granular
information on uninsured deposits could be helpful.\9\
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\9\ Financial Stability Oversight Council 2023 Annual Report.
Available at: <a href="https://home.treasury.gov/system/files/261/FSOC2023AnnualReport.pdf">https://home.treasury.gov/system/files/261/FSOC2023AnnualReport.pdf</a>.
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Following these recommendations and matters for consideration, the
FDIC updated the Risk Management Manual of Examination Policies
(Manual) to
[[Page 63948]]
provide additional guidance for assessing the stability of uninsured
deposits and related concentration risk management practices.\10\
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\10\ Available at: <a href="https://www.fdic.gov/resources/supervision-and-examinations/examination-policies-manual/section6-1.pdf">https://www.fdic.gov/resources/supervision-and-examinations/examination-policies-manual/section6-1.pdf</a> and
<a href="https://www.fdic.gov/resources/supervision-and-examinations/examination-policies-manual/section16-1.pdf">https://www.fdic.gov/resources/supervision-and-examinations/examination-policies-manual/section16-1.pdf</a>.
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While banks are required to provide certain data on deposit
liabilities on the Call Report, including on transaction and
nontransaction deposit accounts and other deposit data described in the
appendix to this document, Appendix: Relevant Information on Deposit
Liabilities Available from the Call Report and other Regulatory Reports
(appendix), they do not report comprehensive data on the composition of
insured and uninsured deposits.
Only banks with $1 billion or more in total consolidated assets
report the estimated amount of uninsured deposits on the Call Report
each quarter.\11\ On an annual basis, institutions also report a subset
of uninsured deposits: preferred deposits, which are uninsured deposits
of states and political subdivisions in the U.S. that are secured or
collateralized as required under state law. Preferred deposits are the
only component of uninsured deposits banks report separately on the
Call Report and are the only type of collateralized deposits reported
on the Call Report.
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\11\ The $1 billion asset-size test is based on the total assets
reported on the prior year's Report of Condition as of June 30.
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Also as described in the appendix, while certain institutions
report information on deposit liabilities through other information
collections, reporting requirements for most of these data collections
are limited to the largest institutions or a subset of all insured
depository institutions (IDIs). In most cases, the granularity of the
data collected on deposits in these reports may also be limited in
informing the efforts herein.
At the same time, the FDIC recognizes that different types of
uninsured deposits may not necessarily behave the same way. For
example, uninsured deposits that are secured by collateral generally do
not have the same risk of loss as other types of uninsured deposits,
although the presence of collateral may not fully mitigate run risk.
Intercompany depositors also may have different incentives than
unaffiliated depositors with respect to withdrawing funds. Because
banks do not report these categories of uninsured deposits on the Call
Report, the FDIC does not have historical data on banking industry
trends for these types of deposits, including how depositors for these
different types of deposits would behave under conditions of economic
or liquidity stress. Furthermore, other types of uninsured depositors
may have various other characteristics that impact the stability and
franchise value of the associated deposits.
Given these observations and recommendations, the FDIC is seeking
information on deposits, including how banks measure or evaluate the
stability of different types of deposits and whether and how banks
monitor collateralized or secured deposits, or intercompany deposits,
such as deposits with affiliates and subsidiaries.
B. Options for Deposit Insurance Reform
Additional deposit data also would inform analysis of the benefits
and costs associated with additional deposit insurance coverage for
certain types of deposits. In May 2023, following the bank failures,
the FDIC published a comprehensive review of deposit insurance,
``Options for Deposit Insurance Reform'' (the report), outlining three
options to reform the nation's deposit insurance system.\12\ The
proposed options require an act of Congress. The report first discusses
the events of March 2023, and then reviews the history of deposit
insurance in the United States. It then discusses the objectives and
possible consequences of deposit insurance, and tools that may be used
to support the objectives and address possible consequences. The report
examines three options for deposit insurance reform that range in their
departure from the status quo: Limited Coverage, Unlimited Coverage,
and Targeted Coverage.
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\12\ Options for Deposit Insurance Reform, FDIC, May 1, 2023.
Available at: <a href="https://www.fdic.gov/analysis/options-deposit-insurance-reforms/report/options-deposit-insurance-reform-full.pdf">https://www.fdic.gov/analysis/options-deposit-insurance-reforms/report/options-deposit-insurance-reform-full.pdf</a>.
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Limited Coverage would maintain the current structure of deposit
insurance in which there is a finite deposit insurance limit that
applies across depositors and types of accounts, while Unlimited
Coverage would provide unlimited deposit insurance. As described in the
report, Targeted Coverage would allow for different levels of deposit
insurance coverage across different types of accounts, with a
particular focus on higher coverage for business payment accounts. The
report does not define precisely ``business payment accounts'' but
suggests that they should reflect business accounts whose purpose is
for payment services and not for investment. The report notes that
although each option has strengths and weaknesses, Targeted Coverage
captures many of the financial stability benefits of expanded coverage
while mitigating many of the undesirable consequences.
Targeted Coverage would provide substantial additional coverage to
business payment accounts without extending similar insurance to all
deposits, which the report suggests could yield large financial
stability benefits relative to its costs. Extending deposit insurance
to business payment accounts may have relatively large financial
stability benefits, with fewer costs from moral hazard relative to
increasing the limit for all accounts, as in the other options.
Further, losses on business payment accounts are likely to have broader
financial stability implications due to the spill-over to payroll,
consumption, and other businesses. One challenge to establishing
Targeted Coverage is deciding how broadly or narrowly to define the
type of accounts eligible for expanded coverage. Further, additional
data could inform efforts to establish a practical definition
consistent with concepts discussed in the report.
Each option for deposit insurance reform contemplated in the report
could have implications for the Deposit Insurance Fund (DIF). Increases
to the deposit insurance limit--whether they apply to all deposits on a
limited or unlimited basis, or only apply to a targeted set of
deposits--would imply the need for a larger DIF to maintain the same
reserve ratio under the Federal Deposit Insurance Act (FDI Act), and
may also have effects on bank risk-taking and liability structure, and
on depositor discipline. Limited information on the volume of deposits
at alternative thresholds and on the volume of deposits that would be
covered under Targeted Coverage makes it difficult to determine the
impact on the DIF.
To inform discussion around any potential increases in deposit
insurance coverage, which would require an act of Congress, the FDIC is
seeking comment on the options described in the FDIC's May 2023 report.
The FDIC is also seeking comment on the definition of ``business
payment accounts'' and any burden or challenges associated with
providing new deposit data items, such as ``business payment accounts''
or similar accounts linked to payroll, vendors, or operations.
C. The Deposit Insurance Fund and Risk-Based Pricing
Data on deposits inform the FDIC's management of the DIF, which is
used to insure deposits and protect the depositors of insured banks,
and to resolve failed banks. A key measure in
[[Page 63949]]
assessing the adequacy of the DIF is the reserve ratio, which is
defined as the net worth of the DIF divided by insured deposits.\13\
Insured deposits are estimated based on banks' reported estimates of
uninsured deposits and total deposit liabilities, as defined by the FDI
Act.
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\13\ 12 U.S.C. 1813(y)(3).
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The DIF is primarily funded by risk-based deposit insurance
assessments. Deposit insurance introduces a degree of moral hazard as
it removes incentives for insured depositors to monitor banks. Risk-
based deposit insurance pricing that charges premiums commensurate with
the risk assumed by banks can mitigate moral hazard.\14\ Risk-based
pricing can also promote fairness, whereby banks that pose higher risk
pay higher premiums; incentivize banks to take less risk; and mitigate
cross-subsidization from lower-risk to higher-risk banks.
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\14\ See Options for Deposit Insurance Reform, FDIC, May 1,
2023, at 35. Available at: <a href="https://www.fdic.gov/analysis/options-deposit-insurance-reforms/report/options-deposit-insurance-reform-full.pdf">https://www.fdic.gov/analysis/options-deposit-insurance-reforms/report/options-deposit-insurance-reform-full.pdf</a>. See also: Ehrlich and Becker (1972), Demirg[uuml][ccedil]-
Kunt and Detragiache (2002), Hovakimian, Kane, and Laeven (2003),
and Shoukry (Forthcoming).
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The FDIC collects information, as appropriate, for purposes of
determining risk of losses at IDIs and economic conditions generally
affecting depository institutions.\15\ However, risk sensitivity in the
deposit insurance assessment system could be improved with additional
data.\16\ For example, liquidity risk measurement in a risk-based
pricing system based on statistical analyses and historical failures is
limited by the data available, as failures due to bank runs have
occurred less frequently in recent decades than insolvency failures.
Changes to risk-based pricing based on bank liability structure and
interest rate risk could improve the risk sensitivity of the FDIC's
risk-based deposit insurance system, and could be enhanced with
additional data.
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\15\ 12 U.S.C. 1817(b)(1)(E)(i).
\16\ The goals of risk-based pricing include additional
objectives, such as transparency. For the purposes of this document,
risk-based pricing is discussed primarily in regard to its ability
to affect bank risk-taking.
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In an effort to better inform analysis of deposit balance trends, a
factor that affects an important measure of DIF adequacy, and improve
risk sensitivity in the deposit insurance assessment system, the FDIC
is soliciting comments on how banks measure or evaluate the stability
of different types of deposits, and, more generally, on what additional
data, including more granular or more frequently reported data, should
be considered for collection.
D. Deposit Data Provided to the General Public
The FDIC is a pre-eminent source of U.S. banking industry research
for analysts, including Quarterly Banking Profiles, working papers, and
banking performance data. This research is based on data reported in
the Call Report and other regulatory reports. The FDIC provides tools,
education, and news updates to help consumers make informed decisions
to protect their assets. The FDIC's Quarterly Banking Profile provides
a comprehensive summary of financial results, including deposit data
and trends, for all FDIC-insured institutions.\17\ The FDIC also offers
a suite of tools and searchable databases to help analysts, bankers,
and the public find information on specific banks, their branches, and
the industry.\18\
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\17\ See FDIC Quarterly Banking Profile. Available at: <a href="https://www.fdic.gov/analysis/quarterly-banking-profile/index.html">https://www.fdic.gov/analysis/quarterly-banking-profile/index.html</a>.
\18\ See FDIC Data Tools. Available at: <a href="https://www.fdic.gov/resources/data-tools/">https://www.fdic.gov/resources/data-tools/</a>.
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The appendix details relevant information on deposit liabilities
that certain banks report or maintain through existing recordkeeping
systems and information collections, including the Call Report and the
Summary of Deposits Survey, among others. However, in most cases, the
granularity of the data collected on deposits in the Call Report and
other regulatory reports may be limited in supporting the efforts
herein.
The Call Report, administered by the FFIEC, is a quarterly report
of an institution's condition and income, and is a primary source of
financial data used for the supervision and regulation of banks. Most
data items collected on the Call Report, including data on deposit
liabilities described in detail in the appendix, are also made
available to the general public and can help consumers and analysts
make informed decisions.
To better inform analysts and the general public, the FDIC is
soliciting comments on deposit data not currently reported in the Call
Report or other regulatory reports, including for uninsured deposits,
and information on whether more detailed or more frequent reporting on
characteristics of or types of deposits could improve the accuracy and
transparency of data reported on the Call Report or other regulatory
reports.
III. Request for Comment
The FDIC is seeking information and comment on deposit data that is
not currently reported in the Call Report or other regulatory reports,
including for uninsured deposits. The FDIC seeks to gather information
on characteristics that affect the stability and franchise value of
different types of deposits and whether more detailed or more frequent
reporting on these characteristics or types of deposits could enhance
offsite risk and liquidity monitoring; inform analysis of the benefits
and costs associated with additional deposit insurance coverage for
certain types of deposits; improve risk sensitivity in deposit
insurance pricing; and provide analysts and the general public with
accurate and transparent data.
Additional information provided through this request, or through
potential enhancements in the granularity of deposit reporting, also
would promote transparency and efficiencies in the bank resolution
process, including estimation of payment to insured depositors and
processing claims that exceed the insurance limit. The benefits from
any enhancements in the granularity of deposit reporting would need to
be considered in conjunction with any increase in regulatory reporting
burden.
The FDIC encourages comments from all interested parties, including
but not limited to IDIs, depositors and financial consumers, businesses
that utilize various types of payroll and payment accounts, consumer
groups, researchers, trade associations, and other members of the
financial services industry. In particular, the FDIC requests input on
the following questions:
Questions on Banks' Internal Deposit Information
Question 1: How do banks measure or evaluate the stability of
different types of uninsured deposits? For example, do banks measure or
track characteristics such as length or type of depositor relationship,
duration, depositor proximity, or rates paid by account type?
a. What are the different types of collateralized or secured
deposits and what are the reasons for collateralization? Do banks
monitor the uninsured portion of collateralized or secured deposits
separately from the insured portion?
b. How do banks monitor intercompany deposits such as deposits with
affiliates, subsidiaries, sweep deposits, or any bank-owned deposit
account?
c. How do banks measure or evaluate the stability of operational
deposits and non-operational deposits?
d. To what extent, if any, do banks rely on deposit categories as
defined for
[[Page 63950]]
regulatory reporting to determine stability?
e. Is there additional data on uninsured deposit components that
banks collect and maintain internally?
f. What additional information would be helpful to the FDIC, the
banking industry, and the public in demonstrating the stability of
uninsured deposits?
Question 2: What are the challenges in calculating and reporting
uninsured deposits on the Call Report?
a. How do banks estimate uninsured deposits for omnibus and other
accounts that contain deposits owned by various parties where the
underlying customer data is not maintained by the bank?
Question 3: As discussed in the appendix, 12 CFR part 370 (part
370) generally requires covered institutions to maintain complete and
accurate records regarding the ownership and insurability of deposits
(except as otherwise provided) and to have an information technology
system that can be used to calculate deposit insurance coverage in the
event of failure. These capabilities would facilitate the FDIC's prompt
payment of deposit insurance and enhance the FDIC's ability to
implement the least costly resolution of these covered
institutions.\19\ However, the FDIC understands that some institutions
that are subject to the requirements of part 370 do not necessarily use
information from their part 370 recordkeeping and insurance calculation
capabilities for purposes of reporting uninsured deposits on the Call
Report. For some part 370 covered institutions, what is the reasoning
for not using the same methodology from their part 370 recordkeeping
and insurance calculation capabilities to report uninsured deposits on
the Call Report?
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\19\ 12 CFR part 370.
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a. For part 370 covered institutions, how long would it take to
effectively use part 370 calculation-generated insured and uninsured
information to report data on Call Report Schedule RC-O,--Other Data
for Deposit Insurance Assessments, instead of other estimated measures?
b. Where other estimated measures are used, has analysis been
performed to evaluate the margin of difference between those estimates
and the calculation produced using part 370 capabilities? If so, what
are those margin differences?
c. Do institutions collect additional deposit information from
customers that is not reported in part 370 output files (e.g. customer
classifications, account categorizations, etc.)
Question 4: For what other types of deposits, which are not already
reported on the Call Report or other data collections, do banks collect
and maintain data internally and at what frequency?
a. How are these types of deposits defined?
b. How does data on these types of deposits help inform analysis of
bank liability structure, risk, and funding stability?
c. Of the data collected and maintained internally, what
information could be provided at little or no burden? What challenges
may occur in reporting this information?
d. Of the information collected and maintained internally, what
information could be provided pertaining to foreign deposits and how
the deposits are payable (dually or not dually payable)?
Questions on Potential Additional Data Items
Question 5: What, if any, additional data, including more granular
or more frequently reported data, should the FDIC, in conjunction with
other members of the FFIEC, consider collecting on the Call Report or
another data collection to better inform the public and agencies'
understanding of different types of depositor behavior? What specific
additional data, such as length or type of depositor relationship,
duration, depositor proximity, or rates paid by account type, would be
the most helpful to collect, if any?
a. Should data collections include particular types of deposits or
uninsured deposits? If so, which types and at what frequency? What are
the benefits or challenges of maintaining and reporting average values
of such data for a given frequency?
b. Should data collections include different measures of
concentrations of deposits, such as by deposit account size, depositor
type, or industry? If so, which thresholds, types, and industries are
appropriate and why?
c. Should collection of additional data be limited to certain
reporting thresholds, based on, for example, consolidated asset size,
amount of the item to be reported, or some other activity-based
threshold? Why or why not? What type of burdens would collection of
additional data place on institutions?
d. Should collection of any additional, more granular, data on
deposits be afforded confidential treatment? If so, please explain why.
e. To what extent should data collections require consistency
across different definitions and information reported on deposits,
including deposit liabilities, operational deposits, and other types of
deposits, between the Call Report and other data collections?
f. How helpful would standardized reporting definitions, including
for operational and non-operational deposits, be to the FDIC, the
banking industry, and the public?
g. If the agencies were to consider collecting additional
information, is there any information that the agencies currently
collect that commenters believe is less useful, overly burdensome, and
should no longer be collected?
Questions on Deposit Data To Inform Conversations on Deposit Insurance
Coverage
As mentioned in section II.B. of this document, the May 2023
report, ``Options for Deposit Insurance Reform,'' notes that Targeted
Coverage would provide substantial additional coverage to meet ongoing
payment and operational needs of businesses, which is expected to yield
large financial stability benefits relative to its costs. However,
Targeted Coverage is one of three options examined in the report, and
each option has strengths and weaknesses. The proposed options require
an act of Congress.
Question 6: If Congress were to consider deposit insurance reform,
what are the pros and cons of the options described in the FDIC's May
2023 report? Do commenters have additional data that could help inform
the discussion?
Question 7: If Congress were to pursue increased coverage for
particular types of deposit accounts, but not all deposits, what type
of deposits should be included?
Question 8: If Congress were to pursue increased coverage for
``business payment accounts,'' as described in the May 2023 report,
what are the specific definitions commenters would recommend and why?
a. What features of an account would indicate that it is a
``business payment account,'' and are these features quantifiable and
readily available?
b. Should such a definition be limited to coverage of accounts
linked to payroll at businesses, include accounts linked to operations
such as payroll, or otherwise be defined? Should such a definition
consider the existing definition for ``operational deposits,'' as
defined in 12 CFR 329.3?
Question 9: What burden or challenges would be associated with
providing new deposit data items, such as ``business payment accounts''
or similar accounts linked to payroll, vendors, or operations?
[[Page 63951]]
Other Comments
Question 10: Please provide any other comment or information that
would be useful for the FDIC to consider.
Appendix: Relevant Information on Deposit Liabilities Available From
the Call Report and Other Regulatory Reports
Certain institutions report or maintain information on deposit
liabilities through existing recordkeeping systems and information
collections, including the Call Report and the Summary of Deposits
Survey, among others. However, in most cases, the granularity of the
data collected on deposits in these reports may be limited in
supporting the efforts herein.
A. Deposit Liabilities on the Call Report
The Call Report is a primary source of financial data used for the
supervision and regulation of banks. Banks file the Call Report
quarterly, as of the last calendar day of March, June, September, and
December. The Call Report consists of a balance sheet, an income
statement, and supporting schedules. The Report of Condition schedules
provide details on assets, liabilities, and capital accounts. The
Report of Income schedules provide details on income and expense
accounts.
The FDI Act requires each IDI to report the total amount of the
liability of the depository institution for deposits in the main office
and in any domestic branch according to the definition of the term
``deposit,'' \20\ and provided other requirements are met.\21\ The FDI
Act also requires the FDIC to collect information from each IDI on a
regular basis on the total amount of all insured deposits, preferred
deposits, and uninsured deposits at the IDI.\22\
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\20\ ``Deposit'' is defined in section 3(l) and ``domestic
branch'' is defined in section 3(o) of the FDI Act; 12 U.S.C.
1813(l) and (o).
\21\ Section 7(a)(4) of the FDI Act; 12 U.S.C. 1817(a)(4).
\22\ Section 7(a)(9) of the FDI Act; 12 U.S.C. 1817(a)(9).
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Institutions report deposit liability information primarily on
Schedule RC-E--Deposit Liabilities and Schedule RC-O--Other Data for
Deposit Insurance Assessments. Additional information for certain
deposit liability items is reported on Schedule RC--Balance Sheet,
Schedule RC-K--Quarterly Averages, and for certain institutions on
Schedule RC-Q--Assets and Liabilities Measured at Fair Value on a
Recurring Basis. Schedule RC-E is also divided into two parts on the
FFIEC 031, Part I, which requests data on deposits in domestic offices,
and Part II, which requests data on deposits in foreign offices
(including Edge and Agreement subsidiaries and International Banking
Facilities).
B. Transaction and Nontransaction Accounts Including Savings Deposits
on the Call Report
Despite certain distinctions on the Call Report, regulatory changes
and the economic environment have blurred the distinctions between some
deposit account categories over time. For example, historically,
regulatory restrictions--such as interest rate caps and withdrawal
limits--delineated between the payment and investment functions of
deposits. Amendments to Regulation D and the repeal of Regulation Q
have removed some of the historical differences.\23\
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\23\ See Options for Deposit Insurance Reform, FDIC, May 1,
2023, at 20-21, for further information. Available at: <a href="https://www.fdic.gov/analysis/options-deposit-insurance-reforms/report/options-deposit-insurance-reform-full.pdf">https://www.fdic.gov/analysis/options-deposit-insurance-reforms/report/options-deposit-insurance-reform-full.pdf</a>.
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For Call Report purposes, with a few exceptions, a ``transaction
account,'' is defined as a deposit or account from which the depositor
or account holder is permitted to make transfers or withdrawals by
negotiable or transferable instruments, payment orders of withdrawal,
telephone transfers, or other similar devices for the purpose of making
payments or transfers to third persons or others or from which the
depositor may make third-party payments at an automated teller machine,
a remote service unit, or another electronic device, including by debit
card.\24\
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\24\ See FFIEC 031 and FFIEC 041 Instructions for Preparation of
Consolidated Reports of Condition and Income, Glossary entry for
``Deposits.'' Available at: <a href="https://www.ffiec.gov/pdf/FFIEC_forms/FFIEC031_FFIEC041_202403_i.pdf">https://www.ffiec.gov/pdf/FFIEC_forms/FFIEC031_FFIEC041_202403_i.pdf</a>.
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Savings deposits are deposits with respect to which the depositor
is not required by the deposit contract, but may at any time be
required by the depository institution, to give written notice of an
intended withdrawal not less than seven days before withdrawal is made,
and that is not payable on a specified date or at the expiration of a
specified time after the date of deposit. For Call Report purposes,
savings deposits (both money market deposit accounts and other savings
deposits) are excluded from transaction accounts.\25\
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\25\ Regulation D (12 CFR part 204) classifies savings deposits
as a type of transaction account. However, for Call Report purposes,
savings deposits are classified as a type of nontransaction account.
See FFIEC 031 and FFIEC 041 Instructions for Preparation of
Consolidated Reports of Condition and Income, Glossary entry for
``Deposits.'' Available at: <a href="https://www.ffiec.gov/pdf/FFIEC_forms/FFIEC031_FFIEC041_202403_i.pdf">https://www.ffiec.gov/pdf/FFIEC_forms/FFIEC031_FFIEC041_202403_i.pdf</a>.
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Banks report transaction and nontransaction accounts by depositor
type on Schedule RC-E, items 1 through 6. Additionally on Schedule RC-
E, banks report components of transaction and nontransaction accounts
as well as maturity and repricing data for time deposits. On Schedule
RC-K, banks report quarterly averages of interest-bearing transaction
accounts and certain components of nontransaction accounts: savings
deposits, time deposits of $250,000 or less, and time deposits of more
than $250,000. On Schedule RC-O, banks reported the number and amount
of noninterest-bearing transaction accounts of more than $250,000 from
2008 through 2013, when such accounts were guaranteed under the
Transaction Account Guarantee Program or provided unlimited deposit
insurance coverage under the Dodd-Frank Wall Street Reform and Consumer
Protection Act.
C. Uninsured Deposits on the Call Report
Currently, banks report estimated uninsured deposits on Schedule
RC-O in the Call Report. Specifically, banks with $1 billion or more in
total assets \26\ report on Schedule RC-O, Memorandum item 2, the
estimated amount of uninsured deposits in domestic offices of the bank
and in insured branches in Puerto Rico and U.S. territories and
possessions, including related interest accrued and unpaid.
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\26\ The $1 billion asset-size test is based on the total assets
reported on the prior year's Report of Condition as of June 30.
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For Schedule RC-O, Memorandum item 2, the estimated amount of
uninsured deposits reported in this item should be based on the bank's
deposits included in Schedule RC-O, item 1, ``Total deposit liabilities
before exclusions (gross) as defined in section 3(l) of the Federal
Deposit Insurance Act and FDIC regulations,'' less item 2, ``Total
allowable exclusions, including interest accrued and unpaid on
allowable exclusions (including foreign deposits).'' In addition, for
some deposits, banks should make a reasonable estimate of the portion
of its deposits that are uninsured using the data available from its
information systems.\27\ In preparing this estimate, in addition to
instructions for specific deposit items, if the bank has automated
information systems in place that enable it to identify, for example,
jointly owned accounts and estimate the deposit
[[Page 63952]]
insurance coverage of these deposits, the higher level of insurance
afforded these joint accounts should be taken into consideration.
Similarly, if the bank has automated information systems in place that
enable it to classify accounts by deposit owner and/or ownership
capacity, the bank should incorporate this information into its
estimate of the amount of uninsured deposits by aggregating accounts
held by the same deposit owner in the same ownership capacity before
applying the $250,000 insurance limit. In the absence of automated
information systems, a bank may use nonautomated information such as
paper files or less formal knowledge of its depositors if such
information provides reasonable estimates of appropriate portions of
its uninsured deposits.\28\
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\27\ See FFIEC 031 and FFIEC 041 Instructions for Preparation of
Consolidated Reports of Condition and Income, SCHEDULE RC-O--OTHER
DATA FOR DEPOSIT INSURANCE ASSESSMENTS, pg. RC-O-15--RC-O-17.
Available at: <a href="https://www.ffiec.gov/pdf/FFIEC_forms/FFIEC031_FFIEC041_202403_i.pdf">https://www.ffiec.gov/pdf/FFIEC_forms/FFIEC031_FFIEC041_202403_i.pdf</a>.
\28\ Ibid.
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For institutions with less than $1 billion in assets that do not
report estimated uninsured deposits, the FDIC calculates estimated
uninsured deposits based on other Call Report data items. For example,
for purposes of the FDIC Quarterly Banking Profile, the FDIC calculates
estimated uninsured deposits for institutions that do not report such
deposits on the Call Report as the amount of deposit and retirement
accounts with balances greater than the standard maximum deposit
insurance amount (SMDIA), currently $250,000, minus the portion that is
insured.\29\ The insured portion is estimated by multiplying the number
of accounts with balances greater than the SMDIA, as reported on the
Call Report, by the SMDIA. The data underlying this calculation comes
from Schedule RC-O, Memorandum 1 subitems.
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\29\ See FDIC Quarterly Banking Profile for First Quarter 2024,
at 38 (definition of ``Estimated uninsured deposits''). Available
at: <a href="https://www.fdic.gov/analysis/quarterly-banking-profile/qbp/2024mar/qbp.pdf#page=38">https://www.fdic.gov/analysis/quarterly-banking-profile/qbp/2024mar/qbp.pdf#page=38</a>.
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For the December 31 reporting period only, institutions report
preferred deposits on Schedule RC-E. Specifically, in Schedule RC-E,
Memorandum item 1.e, banks are required to report preferred deposits
(uninsured deposits of states and political subdivisions in the U.S.
which are secured or collateralized as required under state law). As a
result, data on preferred deposits are available on an annual basis
only, and banks do not report other types of collateralized deposits on
the Call Report. Preferred deposits are the only component of uninsured
deposits banks report separately on the Call Report.
While banks are required to provide certain data on deposit
liabilities on Schedules RC-E and RC-O, banks do not report
comprehensive data on the composition of insured and uninsured
deposits. The FDIC is seeking to further evaluate whether and to what
extent certain types of deposits may behave differently from each
other, particularly during periods of economic or financial stress. For
example, while in the FDIC's view the presence of collateral does not
fully mitigate deposit runoff risk, uninsured deposits that are secured
by collateral may be less likely to run in a liquidity stress event
compared to other types of uninsured deposits, or the collateral may be
subject to a loss in value that may need to be realized. Additional
data on the behavior of these types of uninsured deposits, and the
associated collateral securing the deposits, could provide pertinent
information on the risk of these uninsured deposits.
D. Insured Deposits on the Call Report
Institutions do not report information on total insured deposits on
the Call Report. Certain Memoranda items on Schedule RC-E break out
components of some types of deposits that are above or below the SMDIA.
For example, institutions report brokered deposits of $250,000 or less
(fully insured brokered deposits), time deposits of $250,000 or less,
and fully insured affiliate and non-affiliate sweep deposits.
Estimated insured deposits can be calculated using reported
estimated uninsured deposits. For example, in the FDIC Quarterly
Banking Profile, in general, the FDIC calculates estimated insured
deposits as total deposit liabilities after exclusions minus estimated
uninsured deposits.\30\ As mentioned previously, uninsured deposits for
institutions that do not report estimated uninsured deposits can be
calculated from the Schedule RC-O Memorandum 1, subitems a through d.
This calculated estimate of uninsured deposits can also be subtracted
from deposit liabilities after exclusions to estimate insured deposits.
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\30\ Ibid.
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E. Sweep Deposits on the Call Report
Beginning with the September 30, 2021, Call Report, institutions
are required to report deposits held at the reporting institution by a
customer or counterparty through a contractual feature that
automatically transfers to the reporting institution from another
regulated financial company at the close of each business day amounts
under the agreement governing the account from which the amount is
being transferred, or sweep deposits, on the Memoranda to Schedule RC-
E. Specifically, institutions report sweep deposits based on both fully
insured or not fully insured classification, and affiliate or non-
affiliate classification, in Schedule RC-E, Memorandum items 1.h.(1)
through 1.h.(4). Additionally, institutions report total sweep deposits
that are not brokered deposits in Schedule RC-E, Memorandum item 1.i.
Institutions filing the FFIEC 031 or FFIEC 041 Call Report are required
to report these items quarterly, and institutions filing the FFIEC 051
Call Report are required to report these items semiannually in the June
and December report only. In addition, institutions with $100 billion
or more in total assets report retail sweep deposits based on both
fully insured or not fully insured classification, and affiliate or
non-affiliate classification, in Schedule RC-E, Memorandum items
1.h.(1) through 1.h.(4) subitems on the FFIEC 031 Call Report.
F. Summary of Deposits Survey
The Summary of Deposits (SOD) is the annual survey of branch office
deposits as of June 30 for all FDIC-insured institutions, including
insured U.S. branches of foreign banks. The SOD Survey is a unique
source of information about the number and physical locations of the
tens of thousands of bank offices across the United States. The SOD
data also includes a dollar amount of domestic deposits for each bank
office. While SOD data is informative, it has some limitations due to
the varying methods used by banks for attributing deposits to bank
offices.
G. Recordkeeping for Timely Deposit Insurance Determination
To pay deposit insurance in the event of a bank failure, the FDIC
uses a failed IDI's records to aggregate the amounts of all deposits
that are maintained by a depositor in the same right and capacity and
then applies the SMDIA, currently $250,000 per right and capacity.\31\
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\31\ 12 U.S.C. 1821(a)(1)(C) and (E).
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In 2008, the FDIC adopted a final rule on Large Bank Deposit
Insurance Determination Modernization to ensure that depositors have
access to their funds as soon as possible in the event of a bank
failure. In the event of a failure, the rule allows the FDIC to use the
covered institution's deposit system(s) provisional hold capabilities
to give depositors uninterrupted access to preliminary insurance funds,
while the FDIC works to complete the final insurance determination. The
rule was applicable to banks reporting at least $2 billion in domestic
deposits and either
[[Page 63953]]
250,000 deposit accounts, or $20 billion in total assets.\32\ In 2017,
the FDIC adopted 12 CFR part 370 to implement additional measures to
ensure prompt and accurate payment of deposit insurance to depositors
of the larger IDIs that qualify as covered institutions.\33\
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\32\ 12 CFR 360.9. See 73 FR 41180 (July 17, 2008).
\33\ 12 CFR part 370. See 81 FR 87734 (Dec. 5, 2016). See also
84 FR 37020 (July 30, 2019).
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The FDIC generally relies on the failed IDI's deposit account
records to identify deposit owners and the right and capacity in which
deposits are insured.\34\ Section 7(a)(9) of the FDI Act authorizes the
FDIC to take action as necessary to ensure that each IDI maintains, and
the FDIC receives on a regular basis from such IDI, information on the
total amount of all insured deposits and uninsured deposits at the
IDI.\35\ Part 370 generally requires covered institutions to maintain
complete and accurate records regarding the ownership and insurability
of deposits (except as otherwise provided) and to have an information
technology system that can be used to calculate deposit insurance
coverage in the event of failure. These capabilities would facilitate
the FDIC's prompt payment of deposit insurance and enhance the FDIC's
ability to implement the least costly resolution of these covered
institutions.
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\34\ 12 U.S.C. 1822(c); 12 CFR 330.5.
\35\ 12 U.S.C. 1817(a)(9).
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H. Deposit Liabilities on Other Data Collections
Certain institutions report information on deposit liabilities
through other information collections, including the Complex
Institution Liquidity Monitoring Report (FR 2052a), Report of Deposits
and Vault Cash (FR 2900), the Systemic Risk Report (FR Y-15), and the
Weekly Report of Selected Assets and Liabilities of Domestically
Chartered Commercial Banks and U.S. Branches and Agencies of Foreign
Banks (FR 2644). However, reporting requirements for most of these data
collections are limited to the largest institutions or a subset of all
IDIs. In most cases, the granularity of the data collected on deposits
in these reports may also be limited in informing the efforts herein.
Federal Deposit Insurance Corporation.
By order of the Board of Directors.
Dated at Washington, DC, on July 30, 2024.
James P. Sheesley,
Assistant Executive Secretary.
[FR Doc. 2024-17298 Filed 8-5-24; 8:45 am]
BILLING CODE 6714-01-P
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</html>Indexed from Federal Register on August 6, 2024.
This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.