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Financial Institution Letter

FDIC Issues Procedures for Deposit Insurance Applications from Applicants that are Not Traditional Community Banks

February 10, 2020  |  FIL-08-2020


The FDIC has released a supplement to its Deposit Insurance Application Procedures Manual (Procedures Manual) that addresses deposit insurance applications involving unique or complex proposals. The FDIC has also released updated versions of the Procedures Manual and the publication titled Applying for Deposit Insurance – A Handbook for Organizers of De Novo Institutions (Handbook). Collectively, these publications comprehensively address the deposit insurance application process.

Statement of Applicability to Institutions with Total Assets Under $1 Billion: This Financial Institution Letter applies to all existing and proposed insured depository institutions.


  • The supplement addresses matters relevant to deposit insurance proposals from applicants that are not traditional community banks. It includes definitions of the terms "non-bank" and "non-community bank," and addresses the following main topics: application review processes, field investigations, evaluation of the statutory factors, approval conditions, and written agreements. The supplement does not establish new policy or guidance, or modify existing policy or guidance.
  • The FDIC has also updated the Procedures Manual, which provides instruction to FDIC staff regarding the deposit insurance application process, and the Handbook, which addresses the informational needs of organizers of de novo institutions.
    • These publications address matters pertinent to all types of deposit insurance applications, including pre-filing activities, the application process, and pre-opening efforts.
    • The updates to the Procedures Manual and the Handbook primarily represent technical edits and clarifications.
    • In response to industry feedback, the FDIC has modified its commonly imposed conditions requiring prior approval of business plan changes, to instead require prior notice in most cases.
  • These publications are intended to provide transparency and clarity to the industry and other interested parties regarding the FDIC's deposit insurance application processes.
  • Information regarding deposit insurance applications matters that was clarified in previously issued FILs has been incorporated, as appropriate, into the supplement, the Procedures Manual, and the Handbook; as such, FILs 51-2019, 24-2016, and 56-2014 are hereby rescinded.
  • The FDIC's Applications Mailbox ( is an additional means by which bankers, applicants, and other interested parties may pose questions regarding a specific application or the application process. Interested parties should continue to submit comments regarding pending applications through the FDIC's website.

Suggested Distribution:

FDIC-Supervised Institutions

Suggested Routing:

Chief Executive Officer
Chief Financial Officer

Related Topics:

12 CFR Part 303 (Subparts A and B)
FDIC Statement of Policy on Applications for Deposit Insurance - Effective October 1, 1998
Bank Application Resources
Applications, Notices, & Reporting Forms


Paper copies of FDIC FILs may be obtained through the FDIC's Public Information Center, 3501 Fairfax Drive, E-1002, Arlington, VA 22226 (1-877-275-3342 or 703-562-2200).