Pledge of assets to secure private deposits
Bank may continue to collateralize the uninsured portion of non-public deposits of a depositor where accounts were originally
collateralized prior to enactment of Section 24 of FDI Act.
The following list shows those activities and investments approved by the FDIC under Section 24 of the
Federal Deposit Insurance Act and Part 362 of the FDIC’s Rules and Regulations, 12 C.F.R. Part 362. The list provides
insured state banks and their counsel some initial guidance regarding activities and investments that the FDIC may approve
under Section 24. However, the fact that a particular activity or investment has received FDIC approval in the past does not
affect the obligation of another institution to seek permission from the FDIC to engage in the same or similar activity.
Additionally, the fact that a particular investment or activity has been approved in the past does not restrict the FDIC's review
of future requests to engage in similar activities nor our ability to impose prudential standards on the conduct of that activity.
Finally, it should be borne in mind that since the time any particular application was approved, key statutory or regulatory
changes may have taken place, which might impact how the issues would be treated today.
CAROLINA COMMERCIAL BANK
Application or Notice
Board or Delegated Authority
Date of Approval
Amount of Investment
Percent of Tier I Capital
Applicant seeks permission to continue to pledge bank assets to secure the non-public deposits of two IRA
account holders with aggregate balances in excess of the FDIC deposit insurance limits.
Carolina Commercial Bank