Trade Groups Support FDIC’s Part 370 Recordkeeping Proposal

In a joint comment letter with the Bank Policy Institute and the Consumer Bankers Association yesterday, ABA offered support for a recent FDIC proposal seeking to make changes to Part 370 of its regulations for “recordkeeping for timely deposit insurance determination.” The regulations require banks with at least two million deposit accounts to upgrade deposit recordkeeping so that the FDIC can use the system of a subject bank to make deposit insurance determinations in the event of failure.

While the associations were generally supportive of the proposal, they highlighted several changes and additions that could be made to reduce the compliance burden on covered institutions. Among other things, these include: eliminating the requirement to maintain unique identifiers for grantors of trusts; exempting clearing deposit accounts from Part 370 treatment; and not requiring IT system capability to restrict access to credit balances on loans or on equivalent deposit balances for the corresponding loan customers.