11 Feb The 5 Things to Consider Before Jumping In
FDIC Part 370 rule compliance will be a requirement for covered institutions (CI) in excess of two million depositor accounts in April 2020. Getting a complete insurance determination of all depositor accounts across the enterprise within a 24-hour period will require careful planning and diligent testing. Teams working on technical and functional aspects of the Part 370 recordkeeping requirements must keep the following things in mind before jumping in:
- The rule set is very tricky – one needs to understand the ownership rights and capacities before diving in.
- Exemptions and waivers are possible – FDIC provided “Guidelines for Relief from Part 370” on their website to help CIs.
- Products and services are available to address the data ingestion and insurance determination calculations. Take a look here for some examples.
- Solutions need to scale to be effective – being compliant in April 2020 is not enough. CIs grow, merge and acquire new depositors and systems every day.
- Not much time is left before April 2020 making any kind of homegrown system nearly impossible to complete in time.