FDIC solicits a request for information on deposit data

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Orrick, Herrington & Sutcliffe LLP

On July 30, the FDIC released an RFI for deposit data, specifically data not reported in the Federal Financial Institutions Examination Council’s (FFIEC) call reports or other regulatory reports. The FDIC is seeking comments on the characteristics that affect the stability of deposits and whether more detailed or frequent reporting could enhance offsite risk and liquidity monitoring. The FDIC is concerned with how banks evaluate the stability of different types of deposits and how they monitor collateralized or secured deposits or intercompany deposits.

The RFI posed the following nine questions relating to these issues (in addition to requesting parties provide additional valuable comments):

  1. How do banks measure the stability of different types of uninsured deposits?
  2. What challenges exist in reporting uninsured deposits on the call report?
  3. For Part 370 (12 CFR part 370), what is the reasoning for not using the same methodology from the Part 370 recordkeeping and insurance calculation capabilities to report uninsured deposits on the call report?
  4. What other types of deposits do banks collect and maintain data internally, and how frequently?
  5. What detailed data should the FDIC consider collecting on the call report to inform the public better?
  6. What were the pros and cons of the options described in the FDIC’s May 2023 report?
  7. If Congress were to pursue increased coverage for certain deposit accounts, what types of deposits should be included?
  8. What definitions would commenters recommend if Congress were to increase coverage for “business payment accounts” (from the May 2023 report)?
  9. What challenges exist in providing new deposit data items?

Comments must be received within 60 days of publication in the Federal Register.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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