Field 39 of the Deposit File, DP_Int_Term_No, asks for the term in months. How is this field populated if the term in our system is stated in days?
Divide the days by 30, round down to a whole number and enter that number in field 39. If the value is zero then enter zero.
For example if the term is stated as 10 days, 10 divided by 30 yields 0.33 which would round down to zero, which would be entered in field 39. If the term is stated as 100 days, 100 divided by 30 yields 3.33 which would round to 3, which would be entered in field 39.
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. There is, however, no requirement to analyze the underlying details of the various individuals represented in the account. In the event of failure the FDIC will make arrangements to collect the underlying details.
How and when will the FDIC test our provisional hold functionality and the data files required by the rule?
The following provides an overview of the primary testing steps and procedures banks will be expected to follow to exhibit compliance with rule requirements. The rule as published refers in general terms to the transmission of files between banks and the FDIC using FDICconnect as well as making references to data encryption and certain data validation tools. During the rulemaking process we strived to describe the specifics of the testing environment that involved sending large data files to the FDIC where FDIC systems would process the data and produce other files that the banks would process in return. Given the fact that many institutions will be using confidential production data to test and the implications of transmitting large volumes of data containing non-public personal information we have concluded that the issues involved in this methodology dictate changes to our testing expectations and processes.
The following is a relatively high level description of how we expect Covered Institutions to test rule provisions and document the results. At a later date we will publish more specific guidelines to definitively establish testing requirements and details.
Covered Institutions should expect to independently conduct such testing required to determine compliance with the provisional hold functionality and standard data set creation as provided for in the rule. Institutions should produce documentation attesting to the successful test results with assurances that production systems are in compliance. This self assessment will be tentatively due by May 31, 2010. In certain instances the FDIC may request testing evidence and assessment details earlier if the condition of the financial institution warrants such request. A template of such self assessment will be forthcoming but at minimum should include:
Evidence of the successful creation and placement of provisional holds for deposit, sweep, and other accounts specified in the rule.
Evidence of the successful creation of the following files:
Deposit File – Appendix C
Sweep/Automated Credit File – Appendix D
Hold File – Appendix E
Customer File – Appendix F
Deposit-Customer Join File – Appendix G
Evidence of the successful posting of the following files:
Non-Monetary Transaction File – Appendix A
Debit/Credit File – Appendix B
An inventory listing and reconciliation of deposit account sources, including systems supplying data, ledger accounts, and other ancillary processing systems to the institution’s Call or Thrift Financial Report. For purposes of complying with the Rule, the reconciliation is of the data sources rather than a balancing exercise. A sample of a reconcilement format may be found in the FDIC Assessable Deposit Review Guide, Chapter 4. The Guide is available for download from FDICconnect. In addition the reconciliation should include sweep and other non-deposit accounts for which provisional holds will apply including sweeps, IBFs, foreign deposits, and other accounts considered as part of the Rule’s scope. Additional testing details will be published at a later date as they become available.
Evidence of manual hold processing capabilities to place and remove holds on an individual basis.
A document signed by a bank officer certifying that the testing has been conducted and the institution is in compliance with the rule.
As mentioned above the FDIC will not be asking institutions to transmit encrypted data using the FDICconnect product. The FDIC will select a very small number of institutions to exchange data using a secure FTP connection. All other testing will be conducted at the institution’s site and will not involve sending data to the FDIC. Any data sent using the secure FTP connection will not require encryption. After the February 2010 compliance date, the FDIC will schedule on-site testing. Scheduling and logistics will be determined when the selections have been made.
There will not be an XML validation tool for distribution. Each institution will independently validate their test data.
FDICconnect will not be part of the testing scenario.
Data encryption will not be required.
Any data that the FDIC requests will be transmitted across secure FTP facilities.
The FDIC will select a very small number of institutions to transmit data as a proof of concept exercise.
Covered Institutions will be expected to self test and certify successful results.