The FDIC's grants of exception relief were effective as of November 26, 2019. The FDIC has granted three exception requests pursuant to the FDIC's rule entitled "Recordkeeping for Timely Deposit Insurance Determination," codified at 12 CFR part 370 (part 370). Part 370 generally requires covered institutions...
The American Bankers’ Association (ABA) provided a comment letter to the FDIC advocating for updates to the agency’s outdated and overly broad brokered deposit rules and interpretations. ABA noted that the scope of what is classified as a brokered deposit far exceeds the original intention...
On March 29th the FDIC board approved two proposals to resolve workability issues with its deposit insurance regulations, one of which has significant impact on implementation of the Part 370. The first proposal would amend Part 370 of the FDIC’s regulations for “record-keeping for timely deposit...
A legal memo conducted on behalf of the American Bankers Association (ABA) says the agency’s policy goes beyond statutory intent and places undue restrictions on healthy banks. The ABA memo from February 2019: The FDIC has “ample existing authority” to address the regulation of brokered deposits,...
Each year, Federal Inspectors General are required to identify and report on the top challenges facing their respective agencies. The most recent report from FDIC’s inspector general dated February 14, 2019, outlines the difficulties of regulatory cost-benefit analysis and how to measure and calculate regulatory...
Closing a bank is a whirlwind of activity that begins with shutdown of all bank depositor activities on a Friday evening followed by a complete reconciliation of accounts though the weekend to be ready for depositors on Monday morning (either with a new account or...
FDIC provides procedures for covered institutions (CI) to follow when submitting requests for relief from aspects of Part 370. ...
FDIC Part 370 rule compliance will be a requirement for covered institutions (CI) in excess of two million depositor accounts in April 2020. ...