ABA Proposes Solutions to Critical Issues with Deposit Recordkeeping Rule

Following a recent meeting with FDIC Chairman Jelena McWilliams, ABA today sent a letter to the FDIC calling on the agency to address three critical issues related to its deposit recordkeeping final rule. The 2016 rule requires banks with more than 2 million deposit accounts to upgrade deposit recordkeeping systems to facilitate determination of FDIC-insured deposits should they fail. As the 2020 compliance deadline nears, ABA noted that CEOs at covered institutions may not be ready to certify compliance with the rule (as it requires) if these areas are not addressed.

Specifically, ABA called on the FDIC to accept the systemic depositor identification processes now in place across the industry to satisfy the rule’s signature card requirement for joint accounts. It also asked the FDIC to work with industry to develop contract language to ensure that third-party deposit providers would provide depositor information promptly should a covered bank fail. Finally, ABA asked for blanket exceptions from the recordkeeping requirements for low-balance accounts.