Large-Bank Deposit Insurance Determination Modernization FAQs
What is considered to be a deposit for the purposes of provisional holds and reporting on the Deposit File?
In most cases a Covered Institution’s deposits are located on its deposit applications, but in some cases deposits reside on the General Ledger, loan systems or other systems (such as a human resources system). All deposits residing on a deposit application are subject to the provisional hold process and should be reported on the Deposit file, except that omnibus accounts connected with money market mutual fund sweep accounts are not subject to provisional holds. Funds considered a deposit for Call Report purposes may also rest on the General Ledger or other systems. Generally, these funds do not fall under the scope of this rule. For money market mutual fund omnibus sweep accounts the FDIC would expect the institution to prepare a separate listing or reconciliation of the account which would identify the deposit account from which the sweep originated, the account owner, and the amount. More detail on the treatment of these accounts is provided by clicking the link below:
How do we report Trust or Safekeeping related omnibus accounts that appear on a deposit system?
Many Covered Institutions have trust operations that actively buy and sell a variety of investment products using the banks’ deposit system as a temporary holding vehicle (omnibus accounts) until the funds can be sent elsewhere. If the institution has such deposit system based omnibus accounts related to trust and/or safekeeping operations, the omnibus account is subject to a provisional hold and inclusion in the deposit download just as any other deposit account.
What is a foreign branch deposit?
A foreign branch deposit is a deposit obligation carried on the books and records of a foreign branch of a domestic insured depository institution which is either dually payable or not payable in the United States. In either case, the deposit obligation is not an “insured deposit.” For more details, please see FDIC final rule issued on September 13, 2013:
Do foreign branch deposits fall within the scope of this rule?
Yes, foreign branch deposits are subject to provisional holds and should be reported on the Deposit file. There is a field on the Deposit file 12. DP_Dep_Type for designating a foreign branch deposit as such. See, Appendix C, Field 12. DP_Dep_Type should be populated with “F” for foreign branch deposits.
What is an international banking facility (IBF)?
An IBF is not a physical location, rather a separate set of books maintained by a domestic insured depository institution. An IBF is limited to taking deposits from and making loans to nonresidents of the United States and other IBFs. IBFs are not subject to the same regulations that apply to domestic banking operations.
Do IBF deposits fall within the scope of this rule?
Yes, IBF deposits are subject to provisional holds and should be reported on the Deposit file. A Covered Institution is required to develop and implement a process whereby a provisional hold could be placed on each IBF deposit account on the day of failure by applying a provisional hold percentage to the entire account balance. For IBF deposits, the provisional hold percentage may differ from that applied to domestic deposit or foreign branch deposit accounts. Also, the provisional hold percentage would not vary by account category (i.e., consumer versus non-consumer, and transaction versus non-transaction) as is the case with other deposit accounts.