The American Bankers Association told the FDIC today that covered institutions continue to encounter major challenges in complying Part 370, which addresses timely deposit insurance determination recordkeeping. The rule requires banks with at least two million deposit accounts to upgrade deposit recordkeeping so the FDIC could use the system of a subject bank to make deposit insurance in the event of failure.
In a letter to the FDIC, ABA urged changes to the rule, including allowing alternative recordkeeping for work-in-progress accounts where third parties retain account information or where manual intervention and research is required of the bank. ABA also urged the FDIC to permit institutions to report accounts with missing account information in the pending file after conducting reasonable outreach to customers.
Filling in missing account information for some accounts is outside the control of the covered institutions, ABA wrote, adding that all of the covered institutions have encountered cases where account owners have not provided requisite information.