[Federal Register: December 13, 2005 (Volume 70, Number 238)]
[Proposed Rules]
[Page 73652-73663]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr13de05-21]
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FEDERAL DEPOSIT INSURANCE CORPORATION
12 CFR Chapter III
RIN 3064-AC98
Large-Bank Deposit Insurance Determination Modernization Proposal
AGENCY: Federal Deposit Insurance Corporation (``FDIC'').
ACTION: Advance notice of proposed rulemaking.
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SUMMARY: In view of the significant industry consolidation in recent
years, the FDIC is exploring new methods to modernize its deposit
insurance determination process, whereby the insurance status of each
depositor is determined in the event of failure. Procedures currently
used by the FDIC to determine deposit insurance coverage may result in
unacceptable delays if used for an FDIC-insured institution with a
large number of deposit accounts. In developing a new system to
determine insurance coverage, the FDIC's goals are to minimize
disruption to depositors and communities, and maximize recoveries for
the deposit insurance fund in the event one of the largest insured
institutions should fail. The FDIC is seeking comment on the best means
to accomplish these objectives, and is offering three possible options
for comment. The focus of this Advance Notice of Proposed Rulemaking
(``ANPR'') is on FDIC-insured institutions with the largest number of
deposit accounts, currently expected to include only the 145
[[Page 73653]]
insured institutions with total number of deposit accounts over 250,000
and total domestic deposits of at least $2 billion (``Covered
institutions''). None of these options require that insured
institutions transmit deposit data to the FDIC unless the institution
is in danger of failing.
DATES: Comments must be submitted on or before March 13, 2006.
ADDRESSES: You may submit comments by any of the following methods:
Agency Web site: http://www.FDIC.gov/regulations/laws/federal/propose.html.
Follow the instructions for submitting comments. E-mail: comments@FDIC.gov..
Mail: Robert E. Feldman, Executive Secretary, Attention:
Comments/Legal ESS, Federal Deposit Insurance Corporation, 550 17th
Street, NW., Washington, DC 20429.
Hand Delivered/Courier: The guard station at the rear of
the 550 17th Street Building (located on F Street), on business days
between 7 a.m. and 5 p.m.
Public Inspection: Comments may be inspected and
photocopied in the FDIC Public Information Center, Room 100, 801 17th
Street, NW., Washington, DC, between 9 a.m. and 4:30 p.m. on business
days.
Internet Posting: Comments received will be posted without
change to http://www.FDIC.gov/regulations/laws/federal/propose.html,
including any personal information provided.
FOR FURTHER INFORMATION CONTACT: James Marino, Project Manager,
Division of Resolutions and Receiverships, (202) 898-7151 or
jmarino@fdic.gov or Christopher Hencke, Counsel, Legal Division, (202)
898-8839 or chencke@fdic.gov.
SUPPLEMENTARY INFORMATION:
I. Introduction
The FDIC seeks comment on the best way to improve the deposit
insurance determination process. Three options are presented for
comment.
Option 1 would require Covered institutions to have
installed on their computer systems a routine that, in the event of
failure, would automatically place a temporary hold on a portion of the
balances in large deposit accounts. The percentage hold amount would be
determined by the FDIC at the time of failure, depending mainly on
estimated losses to uninsured depositors. These holds would be placed
immediately prior to the institution reopening for business as a bridge
bank, generally expected to be the next business day. The institution
also would need to be able to automatically remove these holds and
debit the account, if necessary, depending on the results of the FDIC's
insurance determination. The insurance determination would be
facilitated by the institution providing the FDIC, in the event of
failure, with depositor data (name, address, tax identification number,
etc.) in a standard format, including a unique identifier for each
depositor and the insurance category of each account.
Option 2 is similar to Option 1, except the standard data
set would include only information the institution currently possesses.
This option would not require a unique identity for each depositor or
that the institution supply the insurance category for each account.
Option 3 would require that, in addition to Option 1 or
Option 2, the largest 10 or 20 Covered institutions (in terms of the
number of deposit accounts) know the insurance status of their
depositors at any given point in time and have the capability to
automate the placement of hard holds and debit uninsured funds as
specified by the FDIC upon failure.
The FDIC is interested in improving its ability to make insurance
determinations in the insured institutions with the largest number of
deposit accounts, which currently would include insured institutions
with over 250,000 deposit accounts and total domestic deposits over $2
billion. As of June 30, 2005 that would include 145 institutions.
Historically the FDIC has taken responsibility for making an
insurance determination at the time of failure based on the failed
institution's records. A precise deposit insurance determination
requires a specialty system to analyze depositor data and apply the
insurance rules. Under current law an insured depository institution is
not required to calculate by depositor the amount of funds exceeding
the $100,000 insurance limit (by depositor and insurance category).
As part of its normal practice, the FDIC obtains depositor data
only at the time an insured institution is in danger of failing. These
data are received in the weeks or months prior to failure, and are
obtained for the sole purpose of determining the insurance status of
individual depositors and estimating the total amount of insured funds
in the institution. The receipt of such depositor data is necessary for
the FDIC to carry out its insurance function. The options provided in
this ANPR do not alter the FDIC policy regarding the receipt of
depositor information in preparation for the resolution of a failing
insured institution. The FDIC is aware of the potential privacy issues
surrounding the holding of depositor information and has in place
strict safeguards to protect these data.
The FDIC operates under a mandate when handling a failing
institution to structure the least costly of all possible resolution
transactions,\1\ except in the event of systemic risk \2\ and even in
those cases the FDIC must conserve costs. Since the introduction of the
systemic risk exception in 1991 no exceptions to the least-cost
requirement have been granted. The FDIC's least-cost requirement was
intended to reduce resolution cost and instill a greater degree of
market discipline by requiring that losses be borne by uninsured
depositors and non-deposit creditors. The FDIC's claims process clearly
plays a central role in this area.
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\1\ Section 13(c)(4)(A)(ii) of the Federal Deposit Insurance Act
(``FDI Act''), 12 U.S.C. 1823(c)(4)(A)(ii).
\2\ Section 13(c)(4)(G)(i) of the FDI Act, 12 U.S.C.
1823(c)(4)(G)(i).
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When an insured institution fails the FDIC may pay insured
depositors up to the insurance limit (a ``pay-off'') or the FDIC may
sell the failed institution to another FDIC-insured institution (a
``purchase and assumption transaction''). Another option is to
establish a bridge bank \3\ or a conservatorship and transfer deposits
to that institution. Preservation of the deposit franchise of a failed
institution is an important facet of minimizing resolution costs. As a
consequence, the FDIC is most likely to use a bridge bank structure in
the resolution of a Covered institution, although a pay-off or a
purchase and assumption transaction remain possibilities. Establishing
a bridge bank should contribute greatly to customer retention and
minimize potential operational difficulties, which will enhance the
sales premium when the bridge bank is privatized as part of the final
resolution transaction.\4\
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\3\ A bridge bank is a national bank chartered for the purpose
of temporarily carrying on the banking operations of a failed
institution until a permanent solution can be crafted. See 12 U.S.C.
1821(n). The FDIC's bridge bank authority applies only to the
failure of a bank. In the event of the failure of an insured savings
association the FDIC could seek a federal thrift charter that would
be operated as a conservatorship. As with a bridge bank, the new
thrift institution would be a temporary mechanism to facilitate a
permanent resolution structure.
\4\ Bovenzi, John F., ``An FDIC Approach to Resolving a Large
Bank,'' Financial Market Behavior and Appropriate Regulation Over
the Business Cycle, Chicago: Federal Reserve Bank of Chicago, May
2002, pages 56-61.
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The FDIC also has a legal mandate to pay insured deposits ``as soon
as possible'' \5\ after an institution's closure. Although the FDIC has
no statutory requirement to provide access to insured deposits within a
specified time
[[Page 73654]]
after failure it places a high priority on providing access to deposits
promptly to:
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\5\ Section 11(f)(1) of the FDI Act, 12 U.S.C. 1821(f)(1).
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Maintain public confidence in the banking industry and the
FDIC.
Provide the best possible service to insured depositors by
minimizing uncertainty about their status and avoiding costly
disruptions such as returned checks and a limit on their ability to
meet financial obligations.
Mitigate the spillover effects of a failure, which may
include risks to the payments system, problems stemming from depositor
illiquidity and a substantial reduction in credit availability. For
large failures the potential spillover effects can be magnified,
underscoring the importance of a rapid resolution. Effectively
addressing spillover effects minimizes the likelihood of systemic risk.
Retain, where feasible, the franchise value of the failed
institution (and thus minimize the FDIC's resolution costs).
Historically, most insured institution closures have occurred on a
Thursday or Friday. In recent years, the FDIC has made funds available
to the majority of depositors by the next business day, usually the
Monday following a Friday closing.
All of the insured institution failures of the past 10 years have
been of modest size, the largest being Superior Bank, FSB with total
deposits at the time of closure of about $2 billion and roughly 90,000
deposit accounts. This failure pattern does not overshadow the FDIC's
mandate to handle the failure of an insured institution of any size.
Continued industry consolidation has caused the FDIC to reexamine its
approach to conducting a deposit insurance determination, including the
adoption of new technologies and business processes that could greatly
increase the efficiency and timeliness of resolving a failed
institution and getting depositors access to their funds.
Industry consolidation raises practical concerns about the FDIC's
current business model for conducting a deposit insurance
determination. Larger institutions--especially those initiating recent
merger activity--are considerably more complex, have more deposit
accounts, greater geographic dispersion, more diversity of systems and
data consistency issues arising from mergers than has been the case
historically. Implications of industry consolidation over the past 10
years can be seen in the following table. Should such trends continue,
deposits will become even more concentrated in the foreseeable future.
Table 1.--Top Ten Institutions, by Number of Deposit Accounts
[In millions]
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Rank 1995 2000 2005
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1................................ 11.0 36.4 47.8
2................................ 6.5 10.9 29.1
3................................ 3.8 9.0 22.7
4................................ 3.6 7.9 17.4
5................................ 3.5 7.8 16.3
6................................ 3.3 7.2 10.3
7................................ 3.3 6.5 9.0
8................................ 3.2 5.5 8.7
9................................ 3.1 5.1 6.1
10............................... 3.0 5.0 5.0
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Total........................ 44.3 101.3 172.5
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Source: FDIC.
This ANPR discusses regulatory options for a new business model for
insurance determinations where Covered institutions would be required
to facilitate the calculation of the insurance coverage of deposit
accounts. Prior to developing the options discussed below and as part
of its ongoing work to improve the efficiency of the claims process,
the FDIC held meetings with senior examiners from the FDIC and other
Federal banking agencies. Further, the FDIC solicited advice and
opinions from the staff of four large insured depository institutions
and a deposit servicer of large institutions.
After the basic options discussed in this ANPR were developed the
FDIC held meetings with four large providers of deposit software or
servicing to Covered institutions. During these meetings FDIC staff
presented the options along with substantial background on its
insurance determination process and the objectives of the current
claims modernization process. The deposit software vendors/servicers
were asked to consider the feasibility of the options, including
potential costs. Each vendor expressed a strong preference among these
options for Option 2 (described in more detail below). The FDIC's
impression from these meetings was that Option 2 could be incorporated
into the vendor's deposit systems. Based on discussions with these
vendors, staff of the FDIC believes the costs for Option 2 likely would
be fairly modest.
These vendor visits were followed by meetings with the other
Federal banking agencies: The Board of Governors of the Federal
Reserve, the Office of the Comptroller of the Currency and the Office
of Thrift Supervision. Visits also were made to several banking trade
organizations to discuss the options and solicit feedback. Lastly, the
options were presented for comment to the four large insured depository
institutions visited earlier in the process.
The options outlined here cannot be implemented without some
regulatory and financial burden. The FDIC is seeking to minimize these
costs while at the same time ensuring that it can effectively carry out
its mandates to make insured funds available quickly to depositors and
provide a least-cost resolution for Covered institutions. The FDIC
would like comment on the potential industry costs and feasibility of
implementing the options (described below in more detail). The FDIC
also is interested in comments on whether there are other ways to
accomplish its goals that might be more effective or less costly or
burdensome. In other words, what approach or combination of approaches
(which may include new alternatives) most effectively meets this cost/
benefit tradeoff?
Implementation of these or similar options will require that the
FDIC amend its regulations. If changes in the regulations are proposed,
the FDIC will publish a Notice of Proposed
[[Page 73655]]
Rulemaking and afford the opportunity for additional public comment
before any final decision is made.
II. Background
FDIC Insurance Coverage
The basic insurance limit is $100,000 per depositor, per insured
institution. Depositors eligible to receive insurance coverage include
natural persons, legal entities such as corporations, partnerships and
unincorporated associations, and public units. Insurance coverage is
based on the concept of ownership rights and capacities. Deposits
maintained by a person or entity in different ownership rights and
capacities at one institution are separately insured up to the
insurance limit. Deposits maintained in the same ownership rights and
capacities are added together to determine the insurance coverage. The
FDIC's rules and regulations for deposit insurance coverage describe
the categories of ownership rights and capacities eligible for separate
insurance coverage. FDIC refers to these as ``ownership categories''
(see Appendix A for a description of the primary ownership
categories).\6\
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\6\ See also Financial Institution Employee's Guide to Deposit
Insurance, Federal Deposit Insurance Corporation, 2004. This
publication as well as additional information on insurance coverage
is available at http://www.fdic.gov/deposit/deposits/index.html.
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All types of deposits (for example, checking accounts, savings
accounts, certificates of deposit, interest checks and cashier's checks
\7\) that a depositor has at an institution in the same ownership
category are added together before the FDIC applies the insurance limit
for that category. A depositor cannot increase insurance coverage by
dividing funds into different accounts in the same ownership category
at the same institution. Similarly, in the case of joint accounts,
using different co-owner Social Security numbers on different accounts
does not increase insurance coverage. In a deposit insurance
determination, the FDIC relies upon the deposit account records of the
failed institution to determine the ownership of an account and thus
the amount of insurance coverage available.
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\7\ Cashiers' checks, money orders, officers' checks, interest
checks, loan checks or expense checks constitute official items.
Official items are included in the deposit insurance determination
only if they are drawn on the failed bank.
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Current Deposit Insurance Determination Process
Background. The deposit insurance determination process has several
steps. Each step varies in time and complexity, depending on the
institution's characteristics (primarily the number of deposit accounts
and deposit systems).
Closing out the day's business. Generally, on the day of an
institution's failure, all of the day's check processing and deposit
transactions are completed (not including the overdraft decision-making
process that occurs the following morning). The length of this process
can vary across institutions. For larger institutions this process can
run into the early morning hours possibly ending at 4 a.m. or later.
Obtain deposit data. A data file is obtained from the institution
or its servicer. Obtaining usable requisite data from the institution
or its servicer frequently is a time-consuming process. The FDIC will
provide the institution or its servicer with a standard data request.
The standard data request requires the institution to provide
approximately 45 data fields for each deposit account along with
electronic copies of trial balances and deposit application
reconciliations. FDIC technical staff works with the insured
institution until the standard data set requirements are met and the
files transmitted to the FDIC can be processed properly.
Generally, the FDIC has at least 30 days advance warning to plan
and prepare for failures. Data are requested in advance to ensure
delivery capabilities, prove the balancing and reconciliation processes
and make certain all required fields have been included. In instances
in the past, where a large depository institution experienced financial
difficulties, liquidity pressures forced the closing of the institution
before it became capital insolvent. As a consequence, the FDIC is
concerned that lengthy advanced warning and early access may not be
possible or practical for a Covered institution that becomes
financially troubled. More limited access combined with complexities
inherent in large-institution deposit systems--including multiple
deposit systems and significant data volumes--could materially delay
the process of obtaining data necessary to conduct a deposit insurance
determination.
Process deposit data. Data are received and validated (including
reconciliation to the actual trial balance). Using its Receivership
Liability System (``RLS'') the FDIC determines which accounts are fully
insured, which are definitely uninsured and which are possibly
uninsured (pending the collection of further information). The RLS
automatically groups accounts based on the estimated ownership category
and the name(s), address, and tax identification number for each
account. This process is part of the insurance determination performed
on the depositor data received from a failed institution.
FDIC holds/debits based on insurance determination results.
Accounts definitely uninsured are debited for the uninsured amount.
Holds are placed on accounts that are deemed potentially uninsured for
amounts over the insurance limit and the account owner is contacted. If
additional information is required from the depositor, a meeting is
scheduled. These meetings afford the opportunity to collect information
necessary to finalize the insurance determination on the possibly
uninsured depositors.
The typical institution resolved by the FDIC does not have the
capability to post a large volume of holds electronically by batch. In
these cases holds are placed manually usually through the on-line
system. In two failures in the recent past the FDIC has had the ability
to work with programmers prior to the closing to create an automated
method. This required a significant amount of time and availability of
staff prior to the failure. Automatically processing a large number of
holds at closing without pre-failure preparations and testing may
result in significant operational difficulties during and after opening
the new institution for business. In one instance the FDIC discovered
after the fact that the programmed holds could not be removed by
tellers under the direction of FDIC staff. These holds could only be
removed by another program that ran in batch mode. This caused a delay
in releasing funds to insured customers.
FDIC System Upgrades
As part of its claims process review, the FDIC will streamline the
business processes it uses to facilitate a deposit insurance
determination. This will involve developing a new deposit insurance
claims processing system incorporating more advanced technologies to
enhance automation. These changes will improve the FDIC's ability to
process efficiently a large number of accounts and provide timely
customer support to uninsured depositors. In the case of a Covered
institution that is in danger of failing, enhancements to the FDIC's
claims system would be complemented by the options proposed in this
ANPR. In particular, the FDIC is focusing on the collection and
validation of deposit data and the capability of automatically debiting
or placing holds on uninsured or potentially uninsured accounts.
[[Page 73656]]
The Banking Landscape From the Claims Perspective
Industry segmentation. Insured depository institutions can be
divided into two general categories, depending on the unique issues
posed during a potential resolution. The single most important facet
determining the complexity of the claims process is the number of
deposit accounts, although the volume of daily transactions also can be
important. For the purpose of claims process planning the FDIC has
divided the industry into two segments as shown in Table 2.
This segmentation does not result in two homogenous groups. There
are profound differences among institutions in each group. From the
deposit claims perspective the varying characteristics of Covered and
Excluded institutions suggest the need for different claims approaches
and methodologies.
Complexity: Large institutions typically have more accounts and
more complex deposit systems. With Covered institutions the speed of
the claims process could be greatly enhanced by the FDIC obtaining a
timely data download and improving the capability to automatically post
holds or debit uninsured funds.
Table 2.--Industry Segmentation.
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Total
Percent of domestic Percent of
Segment Definition Number total deposit total
(billions)
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Covered............................. Total number of 145 1.6 $3,982 67.1
deposit accounts over
250,000 and total
domestic deposits
over $2 billion.
Excluded...................... All insured 8,735 98.4 1,950 32.9
institutions not
covered.
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Total........................... ...................... 8,880 100.0 5,932 100.0
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Source: FDIC.
Note: Data are as of June 30, 2005.
Resolution structure: The resolution of a Covered institution is
likely to unfold differently compared to one of smaller size. These
differences generally relate to the expected nature of the failure. In
today's environment a critically undercapitalized institution will
receive a supervisory letter indicating it has 90 days to improve its
capital position, otherwise it will be closed (capital insolvency). If
the institution's capital level is not improved during this time, a
failure will occur, typically on a Friday. This process affords the
FDIC substantial advance warning and the opportunity to prepare by
obtaining deposit data up to 90 days in advance of failure and by
having the opportunity to work with the failing institution's
information technology staff.
Covered institutions are more likely to fail due to liquidity
reasons prior to becoming critically undercapitalized (liquidity
insolvency). Most likely, this will be a less orderly event.
Institutions more susceptible to a liquidity insolvency pose greater
problems for the FDIC. Such institutions have a less predictable
failure date; the failure could occur on any day of the week; and pre-
failure access to the institution may be limited because the
institution's insolvency is difficult to anticipate.
Covered insured depository institutions present unique challenges
in the event of failure. For the smaller, less-complex Covered
institutions these challenges may be only modest; for the larger, more
complex members of the group they are more severe. The FDIC is
concerned about both the size and complexity of the deposit operations
of Covered institutions and the speed at which a claims process must be
conducted to make funds available quickly to depositors and maximize
the institution's franchise value.
III. Proposed Deposit Insurance Determination Timeline
General Process
This ANPR presents three options for discussion. Each of these
options would require modifications to the deposit systems of Covered
institutions to facilitate the insurance determination process. The
third option would require the larger Covered institutions to determine
the insurance status of each depositor. In this case the FDIC would
rely upon institution-generated results in the event of failure.
Alternatively, the first two options imply a process similar to that
currently undertaken by the FDIC, but with important distinctions. The
general timeline of the insurance determination process under Options 1
and 2 is outlined below.
Step 1. The institution is closed, typically at the end of the
business day.
Step 2. The institution's nightly deposit cycle is completed, a
process which may run into the early morning hours. This process posts
the day's deposit transactions, ending with the account balance used
for deposit insurance purposes.
Step 3. After the nightly deposit cycle is processed and the ending
balance obtained for each account, the insured institution's deposit
system would post what the FDIC is calling a ``provisional hold'' on
certain large deposit accounts. The capability to post provisional
holds is not a current feature of deposit processing systems and would
have to be specifically created for this purpose. The provisional hold
is a calculated amount based on the account type and balance. Accounts
below a certain threshold (for example, $50,000) would be exempt from a
provisional hold. Based upon an initial analysis of potential losses
from the failed institution, a specified percent (for example, 10
percent) of each account above this size threshold would be subject to
a provisional hold. The actual threshold account size and hold
percentage would be provided by the FDIC the night the institution is
closed, based primarily on estimated institution losses. The threshold
size and hold percentage may vary by account type (for example, demand
and NOW accounts, savings deposits, time deposits and IRAs). Once the
financial institution calculates the provisional hold amounts, holds
must be placed on each affected account. The Hold Code legend should
read ``FDIC Provisional Hold.'' The provisional holds would remain in
place until the insurance determination results are determined by the
FDIC. The FDIC provisional holds would be removed en masse once
insurance determinations have been made by the FDIC. The FDIC will
direct the institution's Operations/IT staff to reverse all provisional
holds. It is anticipated this will be done by using the original
provisional holds file and
[[Page 73657]]
changing it to reverse the provisional holds. The FDIC provisional
holds should be of a nature that they can be overridden only by IT
personnel at the direction of the FDIC if the need arises that
individual provisional holds must be removed prior to the en masse
removal.
Step 4. After the provisional holds are in place the institution
(most likely a bridge bank) is ready to open for business. Posting of
provisional holds must occur prior to the start of the business day
following failure and appear on hold reports and the on-line system.
The ``available balance'' must show the customer balance after the
provisional hold has been posted.
Step 5. The Covered institution also must have the capability to
generate a standard data set of deposit account fields necessary for
the FDIC to conduct the deposit insurance determination. Except as
discussed below for Option 1, the standard data set would be comprised
of information the bank already has on hand. Principal balances,
accrued interest, and record counts captured as part of this process
must be reconciled to the institution's actual trial balance reports or
summary totals reports. A mechanism would need to be in place to
transmit these data quickly to the FDIC or its designated processing
vendor.
Step 6. Upon receipt of the institution's standard data set the
FDIC will process the information to determine the insurance status of
each account. The FDIC will generate one of three possible outcomes for
each account.
1. Account is fully insured: remove the provisional hold. No
further action is required.
2. Account is definitely uninsured: remove the provisional hold and
debit the account in the amount specified by the FDIC.
3. Account is possibly uninsured but further information is
required by the FDIC to make the final determination: remove the
provisional hold and place a regular bank hold \8\ in the amount
specified by the FDIC.\9\
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\8\ Bank holds should have a legend stating ``FDIC Hold'' and
are placed for an unlimited number of days.
\9\ Certain trust accounts and accounts eligible for pass-
through coverage will require additional information to determine
insurance status. The FDIC must obtain this information from the
depositor. This process may take several weeks in the case of a
relatively large Covered institution. The bank hold with the ``FDIC
Hold'' legend will remain in place until results are obtained. The
results of the insurance determination on these accounts will be
passed to the institution (bridge bank or assuming institution) as
they become available. When these accounts are processed, the
deposit insurance determination will be complete.
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The FDIC intends to forward insurance results to be incorporated
into the institution's deposit systems as soon as possible, perhaps as
quickly as the day following the receipt of the standard data set. The
results will dictate debits and holds to be placed by batch in an
automated fashion on deposit accounts. The processing stream would be
as follows: FDIC will notify Operations/IT that results are available.
This notification will trigger a process whereby all provisional holds
are removed en masse using the original file to create the removal
transactions. After provisional holds have been removed debit
transactions and bank holds will be placed on accounts as determined in
the process described above in items 1 through 3.
Provisional Holds
The steps described above would require new features for the
deposit systems of Covered institutions. These features are: (1) The
creation of a standard data set reconciled to the institution's actual
trial balance; (2) the calculation of provisional holds on the basis of
FDIC-specified criteria and placement of provisional holds after the
regular deposit processing is complete for the day; (3) the capability
to remove the provisional holds en masse and (4) the ability to place
bank holds by batch, electronically.
Since provisional holds enhance the FDIC's ability to open a bridge
bank quickly, it substantially increases the potential resale value of
the institution. These holds are necessary to stop the potential
outflow of uninsured funds subject to risk during the first business
day(s) of the bridge bank's operations. At the same time depositors are
provided access to the majority of their funds.
Potential difficulties could arise from provisional holds,
including acceleration in the number of returned items. There is a
tradeoff between holding uninsured funds potentially subject to loss
and quickly making funds available to depositors. The FDIC must strike
a balance in this decision-making process. As a part of this balance,
the FDIC could require that the percentage of the provisional hold
differ between account type.
Historically losses on large insured institutions have been lower
as a percent of assets compared to the smaller, more typical failure.
Large institutions also tend to hold more subordinated debt and other
general creditor claims compared to smaller institutions. These facts
suggest the possibility that the provisional hold percentage will be
fairly modest in the failure of most Covered institutions.
IV. Options
The FDIC has preliminarily identified three options, each of which
is discussed below. The FDIC invites comments on these options, as well
as other suggestions to achieve the objectives identified in this
document. In addition, the FDIC seeks comments on several related
issues. These options are being considered only for Covered
institutions.
The definition of a Covered institution is being actively
considered. At this point the definition includes insured institutions
with at least 250,000 deposit accounts and more than $2 billion in
domestic deposits. These thresholds are subject to further research and
consideration. A limited number of large insured institutions (total
assets over $20 billion) would not fall under this definition because
they have fewer than 250,000 deposit accounts. Inclusion of these
institutions in the definition of ``Covered'' is being considered.
Further, a multi-bank holding company could have at least one Covered
institution while other members do not meet the definition.
Consideration is being given to defining as Covered other members of a
multi-bank holding company as long as at least one of its members meets
the size thresholds listed above.\10\
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\10\ Some members of a multi-bank holding company hold only a
limited number of deposit accounts, perhaps dictating exclusion from
the definition of covered.
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Option 1
Option 1 would require each Covered institution (except those to
which Option 3 would apply) to have in place on an ongoing basis the
ability to:
Identify the owner(s) of each account by using a unique
identifier.
Identify the deposit insurance ownership category of each
deposit account.
Supply to the FDIC a standard data set mapped and
formatted to FDIC specifications and reconciled to the institution's
actual trial balance. (See Appendix B for a preliminary list of data to
be included in the standard data set.)
Calculate and place provisional holds automatically
according to the FDIC's specifications at the end of processing on any
given business day.
Remove provisional holds automatically according to the
FDIC's specifications at the end of processing on any given business
day.
[[Page 73658]]
Add and remove automatically the FDIC-supplied holds/
debits on an as-needed basis.
To ensure compliance the FDIC would test periodically a Covered
institution's ability to produce the required processes.\11\ The
testing process would focus on data quality and accuracy, the ability
to produce quickly a standard data set meeting the FDIC's criteria, the
ability to effectively submit data and the viability of the hold
processes. The FDIC recognizes the sensitivity of depositor data and
the privacy issues that may arise. The FDIC believes it is possible to
conduct an effective testing process while on-site, without the need
for sensitive depositor data to leave the institution's premises.
---------------------------------------------------------------------------
\11\ Options 2 and 3 also would involve a testing process to
determine the overall quality of the results.
---------------------------------------------------------------------------
As each covered institution's system would be tested periodically,
the FDIC should be able to rely upon the unique owner identifier and
the insurance category of each account. Reliance upon these data would
accelerate the insurance determination process. Without these data the
FDIC would have to identify account owners and each account's insurance
category based primarily on the name and address fields and tax
identification numbers, as is the case with the current process.
The FDIC would require certain fields from the customer information
file (``CIF'') system such as CIF number, name, address, taxpayer
identification number and certain fields from the deposit system such
as account number, account name, address, and principal balance. The
data from the CIF file and the deposit systems must be linked. These
data elements will be used to determine account owners and to perform
insurance determinations. It is proposed that Covered institutions have
the data elements mapped and formatted to the FDIC specifications and
available to run on short notice. Further, the Covered institutions
would have available a method to reconcile the file to actual trial
balances to ensure all deposit accounts were captured. Proof of
reconciliation would be required.
One of the elements of the standard data set (as set forth in
Appendix B) is ``product type.'' In connection with this element, an
insured depository institution must identify ``accounts owned by bank''
or ``bank-owned accounts.'' This term means an account that does not
qualify as a ``deposit'' account as defined in the Federal Deposit
Insurance Act. See 12 U.S.C. 1813(l). For example, a depository
institution might establish an account reflecting the collection of
loan payments from borrowers. These collected funds represent income.
They do not represent insured ``deposits'' because the depository
institution is not obligated to make repayment. All such ``bank-owned
accounts'' must be identified in the standard data set.
The volume of data to be provided in deposit/CIF files of Covered
institutions can create time delays. In the event a Covered institution
is viewed as in danger of failing, the institution would be required to
quickly send or transmit data to secure FDIC sites.
Questions. What would be the overall cost to a Covered institution
for developing the capability to automatically post provisional holds,
remove provisional holds and automatically process account debits and
holds based on the insurance determination results? What would be the
overall cost to a Covered institution for developing the capability to
produce a formatted standard data file, link CIF files to deposit files
and prepare balancing and reconciliation schedules? How expensive would
it be for Covered institutions to supply a unique identifier for each
depositor? What would be the cost of supplying the insurance category
for each account? How reliable would be the data identifying each
depositor and account insurance category? Would Covered institutions
have difficulty supplying reliable data for any of the items listed in
Appendix B, such as for bank owned accounts? If so, which ones? Are
Covered institutions able to identify account owners (as opposed to
trustees, managers, beneficiaries, etc.) from their files?
The deposit systems on many Covered institutions use software
purchased from a small group of vendors. To what extent would vendor-
based software changes help mitigate the overall implementation costs
of this program? Could a vendor develop the standard data set and
program to pull the data into the specified format for multiple
institutions or does each institution have unique details that would
prevent this from occurring?
Some Covered institutions may use a servicer to process deposit
accounts, and some Covered institutions may share the same deposit
servicer. To what extent would implementation changes made by the
servicer mitigate the costs of this program?
To meet the proposed standard data set requirement, institutions
may have to link records from the CIF and the deposit systems or
provide the key or linking elements so data from the CIF can be linked
to individual account owners. This would be more complex than a
standard data set that only included items from the deposit systems,
but it would yield substantial benefits to the FDIC. Once the systems
had been developed and tested, how much longer would it take for an
institution to prepare a standard data set that included CIF and
deposit system items, compared to one that included only deposit system
items?
The FDIC would require transmitted deposit balances to reconcile to
the actual trial balance, both balance dollar amounts and the record
count. How does reconciliation affect timeliness? Can the process be
developed in advance and automated?
What is the most effective way of transmitting data to the FDIC?
Option 2
Option 2 would require each Covered institution to have in place on
an ongoing basis the ability to:
Supply to the FDIC a standard data set mapped and
formatted to FDIC specifications and reconciled to the institution's
actual trial balance. (See Appendix B for a preliminary list of data to
be included in the standard data set.)
Calculate and place provisional holds automatically
according to the FDIC's specifications at the end of processing on any
given business day.
Remove provisional holds automatically according to the
FDIC's specifications at the end of processing on any given business
day.
Add and remove automatically the FDIC-supplied holds/
debits on an as-needed basis.
The primary difference between Options 1 and 2 rests with the
omission in Option 2 of the requirements to supply a unique identifier
for each depositor and identify the insurance category of each deposit
account. The data elements included in the standard data set also may
vary somewhat from those in Appendix B.
Question: What is the likely cost of Option 2? What are the
potential cost savings to Covered institutions from Option 2 compared
to Option 1? Are there any likely operational difficulties in
implementing Option 2?
Option 3
Option 3 would require the very largest of the Covered institutions
to know the insurance status of deposit accounts at any given point in
time.\12\
[[Page 73659]]
Upon failure, the institution must be able to place debits/holds
automatically for uninsured deposits in an amount specified by the
FDIC, so that the institution can be operational the following business
day. The FDIC is considering this option only for the largest 10 or 20
Covered institutions while, if used, the remaining Covered institutions
would meet requirements similar to those outlined under Options 1 or 2.
Limiting the scope of this option to the largest Covered institutions
would help mitigate implementation costs as well as speed the insurance
determination process for the largest, most complex of the Covered
institutions.
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\12\ This requirement would not include deposit accounts for
which the Covered institution does not ordinarily possess the
information to make the determination, such as accounts with pass-
through coverage (brokered deposit accounts and trust accounts, for
example) and certain informal trust accounts (also referred to as
either ``payable-on-death'' or ``in-trust-for'' accounts) where
information on beneficiaries may be necessary for the determination.
---------------------------------------------------------------------------
This option would be more expensive for Covered institutions than
Options 1 or 2, but it could yield additional benefits. Depositors
could benefit from the institutions' ability to provide information
about insurance status. If an institution were to fail, this option
provides that the insurance status of most depositors would be known at
the point of failure. As a consequence, some depositors could receive a
larger portion of their funds more quickly under this option compared
to the provisional hold process contemplated in Options 1 and 2.
As with Options 1 and 2, the FDIC would test the accuracy of
systems put in place if this Option is adopted. Under these
circumstances the FDIC should be able to rely upon the results
generated by the insured institution for the initial deposit insurance
determination.
Questions. How expensive would this option be compared to Options 1
or 2? Do the additional benefits merit the additional cost? Are there
other reasons why this approach should be preferred or rejected? How
extensive would the FDIC audit have to be to determine whether
institutions are correctly calculating insurance coverage?
Other Potential Options
The FDIC invites comments on all aspects of this proposal. In
addition, the FDIC solicits suggestions on alternative means of meeting
the objective of conducting a timely insurance determination on Covered
insured institutions.
Question. Is there a different approach that would accomplish the
same objective at a lower financial and regulatory cost?
Appendix A.--Primary FDIC Deposit Insurance Categories
------------------------------------------------------------------------
Insurance category Description
------------------------------------------------------------------------
1. Single Ownership.......... Funds owned by a natural person including
those held by an agent or custodian,
sole proprietorship accounts and
accounts that fail to qualify in any
other category below. Coverage extends
to $100,000 per depositor.
2. Joint Ownership........... Accounts jointly owned as joint tenants
with the right of survivorship, as
tenants in common or as tenants by the
entirety. Coverage extends to $100,000
per co-owner.
The account title generally must
be in the form of a joint account
(``Jane Smith & John Smith'').
Each of the co-owners must sign
the account signature card. (This
requirement has exceptions, including
certificates of deposit.)
The withdrawal rights of the co-
owners must be equal.
3. Revocable Trust........... Accounts whereby the owner evidences an
intention that upon his or her death the
funds shall belong to one or more
qualifying beneficiaries. For each
owner, coverage extends to $100,000 per
beneficiary.
The title of the account must
include ``POD'' (payable-on-death) or
``trust'' or some similar term.
The beneficiaries must be
specifically named in the account
records. (This requirement applies to
informal ``POD'' accounts but does not
apply to formal ``living trust''
accounts.)
The beneficiaries must be the
owner's spouse, children, grandchildren,
parents or siblings.
4. Irrevocable Trust......... Accounts established pursuant to an
irrevocable trust agreement. Coverage
extends to $100,000 per beneficiary.
The account records must
indicate that the funds are held by the
trustee pursuant to a fiduciary
relationship.
The account must be supported by
a valid irrevocable trust agreement.
Under the trust agreement, the
grantor of the trust must retain no
interest in the trust funds.
For ``per beneficiary''
coverage, the interest of the
beneficiary must be ``non-contingent.''
5. Self-Directed Retirement.. Individual retirement accounts under 26
U.S.C. Sec. Retirement 408(a),
eligible deferred compensation plans
under 26 U.S.C. Sec. 457, self-
directed individual account plans under
29 U.S.C. Sec. 1002 and self-directed
Keogh plans under 26 U.S.C. Sec.
401(d). Coverage extends to $100,000 per
owner or participant.
The account records must
indicate that the account is a
retirement account.
The account must be an actual
retirement account under the cited
sections of the Tax Code.
6. Corporation, Partnership Accounts of a corporation, partnership or
or Unincorporated unincorporated association. Coverage
Association. extends to Unincorporated $100,000 per
entity.
The account records must
indicate that the entity is the owner of
the funds or that the nominal
accountholder is merely an agent or
custodian (with the entity's ownership
interest reflected by the custodian's
records).
The entity must be engaged in an
``independent activity.''
The entity must not be a sole
proprietorship (which is treated as a
single ownership account).
7. Employee Benefit Plan..... Deposits of an employee benefit plan as
defined at 29 U.S.C. 1002, including any
plan described at 26 U.S.C. 401(d), and
also deposits of an eligible deferred
compensation plan described at 26 U.S.C.
457. Coverage extends to $100,000 per
participant.
The account records must
indicate that the funds are held by the
plan administrator pursuant to a
fiduciary relationship.
The account must be supported by
a valid employee benefit plan agreement.
For ``per participant''
coverage:
[cir] The interests of the participants
must be ascertainable and non-
contingent.
[cir] The institution must have been well
capitalized (or adequately capitalized
in some cases) when the initial and
subsequent deposits were made.
[[Page 73660]]
8. Public Unit............... Funds of ``public units'' or ``political
subdivisions'' thereof. Coverage extends
to $100,000 for interest bearing
deposits and $100,000 for non interest
bearing deposits for each official
custodian of the public unit or
subdivision.
For separate coverage for the
non interest bearing deposits, the
insured financial institution must be
located (including branch locations) in
the same state as the public unit.
The account records must
indicate that the funds are held by the
custodian in a custodial capacity.
For ``per custodian'' coverage,
the custodian must be a separate
``official custodian.''
For ``per subdivision''
coverage, the governmental entity must
be a separate ``political subdivision.''
------------------------------------------------------------------------
Appendix B. Data Elements Included in the Standard Data Set
This appendix presents a standard data request containing proposed
data fields to be used by the FDIC to determine the insured status of
each account. The proposed file is divided into four record types:
Header, Deposit, Hold, and Customer. It would be preferred that all
data are included in one file but, if necessary due to system
constraints, multiple files might be used. For identification purposes
the Header record in each file must be created. If data or information
are not maintained or do not apply, a null value in the appropriate
field should be indicated.
The following is a list of the data fields proposed to be included
in the file with explanations of the data being requested. The fields
are listed in the order they would appear in the file.
Header Record
The Header Record provides information specific to the institution,
the effective date of the data and the date and time the file was
created. The Header Record must be at the beginning of each file if
multiple files are submitted.
------------------------------------------------------------------------
Field name FDIC field description
------------------------------------------------------------------------
1. HD--Record--ID............ Record ID Enter ``1'' in this field.
1. HD--Acct--Numb............ Header Account Number Enter
``0000000000000000'' in this field.
1. HD--File--Date............ File Date--This field identifies the ``as-
of-date'' of the file. Enter the
effective date of the data being
supplied in this request. Must be
entered in MMDDYYYY format.
1. HD--FI--Name.............. Financial Institution Name--Enter the
institution's name as it appears on the
FDIC Certificate.
1. HD--FI--Number............ Financial Institution Number--Enter the
institution's FDIC certificate/
institution number.
1. HD--Dt--Created........... Date & Time Created--Enter the date and
time in MMDDYYYYHHmmSS format.
------------------------------------------------------------------------
Deposit Record
The Deposit Record provides information specific to deposit account
balances and account data. Fields 14-27 relate to the account name and
address information. Some systems provide for separate fields for
account title/name, address, city, state, ZIP, and country, all of
which are parsed out. Other systems may simply provide multiple lines
for name, address, city, state, ZIP, with no distinction. Populate
fields that best fit system data--either fields 14-21 or fields 22-27.
------------------------------------------------------------------------
Field name FDIC field description
------------------------------------------------------------------------
0. DP--Record--ID............ Record ID--Enter ``2'' in this field.
0. DP--Acct--Numb............ Account Number--The unique number
assigned by the institution to this
account.
0. DP--Acct-- Numb--ID....... Account Number ID--Account number field
that further identifies the account. May
be used to identify separate deposits
tied to this account where there are
different processing parameters, i.e.
interest rates, maturity dates, but all
owners are the same.
0. DP--Tax--ID............... Tax ID--Provide the tax ID number
maintained on the account. For consumer
accounts, typically, this would be the
primary account holder's Social Security
number. For business accounts it would
be the Federal tax identification
number.
0. DP--Tax-- Code............ Tax ID Code--This field should identify
the type of the tax ID number. Valid
values are:
S = Social Security number.
T = Federal tax identification
number.
O = Other.
0. DP--Branch................ Branch--This field should identify the
branch associated with the account. It
may be where the account was originally
opened.
0. DP--Cost --Center......... Cost Center--Identifier used for
organization reporting or ownership of
the account. It may be the same as the
Branch number.
0. DP--Owner --Ind........... Customer Owner Indicator--This field is
used to identify the type of ownership.
This information will assist the FDIC to
further categorize the account into the
FDIC insurance categories. Valid values
are:
S = Single or primary owner
J = Joint or secondary owner
(also include DBA's in this code)
T = Trust account
P = Partnership account
C = Corporation.
B = Brokered deposits
O = Other
[[Page 73661]]
0. DP--Prod --Type........... Product Type--This field is used to
identify the type of the product from a
customer perspective. This information
will assist the FDIC to properly
categorize the account into the FDIC
insurance categories. Valid values in
the field are:
CON = Personal or consumer
accounts.
BUS = Business.
NPR = Non-profit accounts.
GOV = Accounts held by
government entities (city, state,
political subdivisions).
FIN = Accounts held by other
financial institutions.
INT = Internal accounts or bank-
owned accounts.
OTH = Other.
0. DP--Prod--Cat............. Product Category--This is a broad
classification of products and accounts.
Valid values in the field are:
DDA = Non-interest bearing
checking accounts.
NOW = Interest bearing checking
accounts.
MMA = Money market accounts.
SAV = Savings accounts and money
market savings accounts. This includes
any interest bearing accounts with
regulated withdrawal requirements.
CDS = Time deposit accounts and
certificate of deposit accounts. Include
any accounts with specified maturity
dates that may or may not be renewable.
REP = Repurchase agreements.
Include any accounts supported by an
agreement to repurchase the deposit at a
specified date and interest rate, and is
secured by designated securities owned
by the institution.
IRA = Individual retirement
accounts.
OTH = Other.
0. DP--Ret --Ind............. Retirement Indicator--This field is used
to identify whether the account is
considered any type of retirement
product. Valid values are:
Y = Yes, the account is a
retirement account.
N = No, the account is not a
retirement account.
0. DP--Stat--Code............ Status Code--Include only the following
status or condition of the account.
Valid values are:
O = Open.
C = Closed.
D = Dormant.
I = Inactive
0. DP--Short--Name........... Short Name--This field will assist in
creating an alpha list of accounts. The
format preference for personal accounts
is last name or partial last name
followed by first name. For business
accounts enter the name of the account.
Variances to this should be explained in
a Mapping document. If a similar field
does not exist, create a ``Short Name''
by concatenating data using related
fields.
0.DP--Acct--Title--1......... Account Title Line 1--Two lines (fields
14 & 15) are provided to enter account
styling or titling of the account. These
data will be used to identify the owners
of the account.
0. DP--Acct --Title--2....... Account Title Line 2--Additional account
title line.
0. DP--Address-- Line--1..... Address Line 1--Two lines (fields 16 &
17) are provided to enter the street, PO
box, suite number, etc. of the address.
0. DP--Address-- Line--1..... Address Line 2--Additional address line.
0. DP--City.................. City--Enter the city associated with the
mailing address.
0. DP--State................. State--Enter the state abbreviation
associated with the mailing address.
0. DP--ZIP................... ZIP--This field allows for the ZIP+4 code
associated with the mailing address.
0. DP--Country............... Country--This field should identify the
country associated with the mailing
address. Provide the name of the country
or the standard country code.
0. DP--NA-- Line--1.......... Name or Address Line 1--Six lines (fields
22-27) are provided to enter the name
and/or the account mailing address if
your system does not distinguish
particular address lines.
0. DP--NA-- Line--2.......... Name & Address Line 2--Additional name
and/or address line.
0. DP--NA--Line --3.......... Name & Address Line 3--Additional address
line.
0. DP--NA--Line --4.......... Name & Address Line 4--Additional address
line.
0. DP--NA--Line --5.......... Name & Address Line 5--Additional address
line.
0. DP--NA--Line --6.......... Name & Address Line 6--Additional address
line.
0. DP--Cur--Bal.............. Current Balance--This amount represents
the current balance in the account at
the end of business on the effective
date of this file. This balance should
not be reduced by float or holds. For
CDs and time deposits, it should reflect
the principal balance plus any interest
paid and available for withdrawal that
is not already included in the
principal. The total of all Current
Balances in this file should reconcile
to the total liabilities on the
financial institutions general ledger.
0. DP--Int--Rate............. Interest Rate--The current interest rate
in effect for interest bearing accounts.
0. DP--Bas--Days............. Basis Days--Indicates the basis on which
interest is to be paid. Valid values
are:
1 = 30/360.
2 = 30/365.
3 = 365/365 (actual/actual).
0. DP--Int--Type............. Interest Type--Indicates the type of
interest to be paid. Valid values are:
S = Simple.
D = Daily compounding.
C = Continuous compounding.
O = Other.
0. DP--Int--Factor........... Interest Rate Daily Factor--This field
should reflect the daily interest rate
factor for generating interest.
0. DP--Acc--Int.............. Accrued Interest--This amount should
reflect the amount of interest that has
been earned but not yet paid to the
account as of the date of the file.
0. DP--Lst--Int--Pd.......... Date Last Interest Paid--This should
indicate the date thru which interest
was last paid to the account. Must be
entered in MMDDYYYY format.
[[Page 73662]]
0. DP--Int-- Pd--YTD......... Interest Paid YTD--The amount of interest
that has been paid to the account this
year. Must be entered in MMDDYYYY
format.
0. DP--Nxt --Mat............. Date Next Maturity--For CD and time
deposit accounts, this is the next date
the account is to mature. For non-
renewing CDs that have matured and are
waiting to be redeemed this date may be
in the past. Must be entered in MMDDYYYY
format.
0. DP--Res --Acct--Ind....... Reserve Account Indicator--Identifies
accounts with a reserve or overdraft
protection feature tied to this account
and is not identified by another account
number or identifier. It is not an
Overdraft Limit that allows the deposit
account to be overdrawn. Rather, it is
considered a ``loan'' to be advanced to
the account in the event of an
overdraft.
0. DP--Res-- Out--Bal........ Reserve Account Outstanding Balance--
Provide the outstanding balance of a
reserve or overdraft protection feature.
This balance is not reflected in the
accounts deposit current balance. This
is not an Overdraft Limit. Rather, in
the event that proceeds are advanced to
cover an overdraft, the balance that
remains outstanding to be paid back to
the account. This balance may include a
finance charge.
0. DP--Lst--Deposit.......... Date Last Deposit--This date should
reflect the last deposit transaction
posted to the account. For example, a
deposit that included checks and/or
cash. Must be entered in MMDDYYYY
format.
0. DP--Open--Dt.............. Account Open Date--This date should
reflect the date the account was opened.
If the account had previously been
closed and re-opened, this should
reflect the most recent re-opened date.
Must be entered in MMDDYYYY format.
------------------------------------------------------------------------
Hold Record
The Hold Record provides information related to any holds on an
account. If an account has more than one hold, additional Hold Records
may be provided.
------------------------------------------------------------------------
Field name FDIC field description
------------------------------------------------------------------------
2. HD--Record--ID............ Record ID--Enter ``3'' in this field.
2. HD--Acct--Numb............ Account Number--The account number
associated with the hold. This should be
the same as the account number in
Deposit Record field 2.
2. HD--Hold--Amt............. Hold Amount--Dollar amount of the hold.
2. HD--Hold--Reason.......... Hold Reason--Reason for the hold. Valid
values are:
LN = Loan collateral hold.
UC = Uncollected funds hold.
OT = Other--bank defined.
2. HD--Hold--Desc............ Hold Description--Description of the hold
available on the system.
2. HD--Hold--Days............ Hold Days--The Number of days the hold
was/is intended. May be used instead of
an expiration date.
2. HD--Hold--Start--Dt....... Hold Start Date--The date the hold was
initiated. Must be entered in MMDDYYYY
format.
8. HD--Hold--Exp--Dt......... Hold Expiration Date--The date the hold
is to expire. Must be entered in
MMDDYYYY format. May be used instead of
number of hold days.
------------------------------------------------------------------------
Customer Record
The Customer Record provides information related to each customer
associated with an account. Therefore, multiple customer records
associated with each deposit account number found in the Deposit Record
should be indicated.
Fields 8-11 relate to the customer name. Some systems provide for
separate fields for account name: ``last name'' and ``first name'' for
personal accounts or ``company name'' for business accounts, all of
which are parsed out. Other systems simply provide one line for a name.
Populate fields that best fit system data.
Fields 12-17 relate to customer address information. Some systems
provide for separate fields for address, city, state, ZIP, and country,
all of which are parsed out. Other systems may simply provide multiple
lines for name, address, city, state, ZIP, with no distinction. Fields
14-18 are provided if your systems do not distinguish between the
different elements associated with a name and address. Populate fields
that best fit system data--either fields 12-17 or fields 14-18.
------------------------------------------------------------------------
Field name FDIC field description
------------------------------------------------------------------------
1. CS--Record--ID............ Record ID--Enter ``4'' in this field.
2. CS--Acct--Numb............ Account Number--The deposit account
number. Should be the same as the
account number in Deposit Record field
2.
3. CS--Cust--Numb............ Customer Number--The number assigned to
the customer in the customer information
system.
4. CS--Tax--ID............... Customer Tax ID Number--Provide the tax
ID number on record for the customer.
5. CS--Tax--Code............. Customer Tax ID Code--This field should
identify the type of the tax ID number
of the customer. Valid values are:
S = Social Security number.
T = Federal tax identification
number.
F = Foreign accounts.
O = Other.
[[Page 73663]]
6. CS--Rel--Code............. Relationship Code--This code indicates
how the customer is related to the
account. Valid values are:
P = Primary owner.
S = Secondary owner.
B = Beneficiary.
T = Trustee.
O = Other.
U = Unknown.
7. CS--Bene--Code............ Beneficiary Type Code--If the customer is
considered a beneficiary, enter the type
of account associated with this
customer. This includes beneficiaries on
retirement accounts, trust accounts,
minor accounts, and payable-on-death
accounts. Valid values are:
I = IRA.
T = Trust--irrevocable.
R = Trust--revocable.
M = Uniform gift to minor.
P = Payable on death.
O = Other.
8. CS--Name.................. Customer Name--The name of the customer.
Provide in the Mapping document the
typical format the bank practices for
business customers and personal/
individual customers; i.e., last name
first, first name last.
9. CS--Last--Name............ Customer Last Name--The last name of the
individual/personal customer.
10. CS--First--Name.......... Customer First Name--The first name of
the individual/personal customer.
11. CS--Comp--Name........... Customer Company Name--The company name
of the business customer.
0. CS--Address--1............ Address Line 1--Two lines (fields 10 &
11) are provided to enter the street,
P.O. box, suite number, etc. of the
address.
0. CS--Address--2............ Address Line 2--Additional address field.
0. CS--City.................. City--Enter the city associated with the
mailing address of the customer.
0. CS--State................. State--Enter the state abbreviation
associated with the mailing address of
the customer.
0. CS--ZIP................... ZIP--This field allows for the ZIP+4 code
associated with the mailing address of
the customer.
0. CS--Country............... Country--This field should identify the
country associated with the mailing
address. Provide the name of the country
or the standard country code.
0. CS--NA--Line--1........... Customer Name & Address Line 1--The name
and/or address of the customer.
0. CS--NA--Line--2........... Customer Name & Address Line 2--
Additional name and/or address line.
0. CS--NA--Line--3........... Customer Name & Address Line 3--
Additional address line.
0. CS--NA--Line--4........... Customer Name & Address Line 4--
Additional address line.
0. CS--NA--Line--5........... Customer Name & Address Line 5--
Additional address line.
0. CS--Birth--Dt............. Customer Birth Date--The birth date on
record for the customer. Must be entered
in MMDDYYYY format.
0. CS--Telephone Customer.... Telephone Number--The telephone number on
record for the customer.
0. CS--Email................. Customer Email Address--The email address
on record for the customer.
------------------------------------------------------------------------
* * * * *
Dated at Washington, DC, this 5th day of December, 2005.
By order of the Board of Directors.
Federal Deposit Insurance Corporation.
Robert E. Feldman,
Executive Secretary.
[FR Doc. 05-23986 Filed 12-12-05; 8:45 am]
BILLING CODE 6714-01-P