Large-Bank Deposit Insurance Determination Modernization FAQs
Most Common On-Site Review Issues
The rule requires an extract of depositor and customer data to be provided in a standard format in five files: Deposit, Hold, Sweep/Automated Credit Account, Customer, and Deposit-Customer Join files.
Based upon the FDIC’s experience from previous on-site reviews, what are the most common issues found within each data file?
Data accuracy and completeness
The most common issues related to the Deposit file consist of a lack of data accuracy and completeness. The following are some data fields that are prone to mistakes.
- 8. DP_Tax_ID: account does not have tax ID or any type of unique identifier
- 9. DP_Tax_Code: cannot clearly identify what type of code reported in 8. DP_Tax_ID, i.e., SSN, TIN, or Other
- 11. DP_Cost_Center: cost center code or general ledger code not reported
- 12. DP_Dep_Type: domestic or foreign branch deposits not clearly labeled
- 13. DP_Currency_Type: all amounts reported in the Deposit file should be in US Dollars with the originating currency code reported here
- 14. DP_Ownership_Ind: ownership indicator is a key data field for FDIC insurance determination.
- The Deposit file provides two sets of data fields to report names and addresses. Parsed names and addresses can be reported in 17. DP_Acct_Title_1 through 27. DP_Country. Unparsed names and addresses can be reported in 28. DP_NA_Line_1 through 33. DP_NA_Line_6. Most Covered Institutions report either parsed or unparsed names and addresses, but not both.
- If parsed name and address data fields are used, then city, state, zip, and country code should be reported accordingly. The country name should be provided in the country name data field (27. DP_Country) (up to 10 characters) or follow the standard two-digit IRS country code table.
- 39. DP_Int_Term_No: this is the CD term in months. A one-year CD should report 12 in this data field. Do not report the frequency that interest accrues, or number of months until maturity.
- 42. DP_Sweep_Code: a value “Y” means this deposit account has sweep investment vehicle product accounts linked to it.
- 47. DP_Deposit_Class_Type and 48. DP_Product_Class_Cde: it is important to populate these two data fields as accurately as possible. It is related to the provisional hold calculation and insurance determination.
The first 6 fields are key fields in the Deposit, Hold and Sweep files and should match each other exactly. Fields 2 to 7 in the Join file should match exactly fields 1 to 6 in the Deposit file. Field 1 (1. CS_Cust_Identifier), of both the Customer and Join files should also match exactly. These six account identifier fields should be used consistently in all files to ensure proper file linkages.
The most common issues related to the Hold file consist of mapping issues, incorrect hold calculations, missing files, incorrect balances, and special characters.
For example: In many instances, records found in the Hold file do not have a corresponding record in the Deposit file. Covered Institutions should ensure that data contained in the Hold file can be matched with data in the Deposit file.
Covered institutions should ensure correct hold amounts are placed on accounts. Please note the Hold file should contain deposit holds, both bank and FDIC holds, but not sweep investment holds.
For accounts with existing bank holds, a new FDIC provisional hold may result in a negative Available Balance. This is acceptable. Do not alter the calculated FDIC provisional hold amount to make the available balance zero. Instead, leave the available balance negative. This is to protect the FDIC’s interest in the event bank holds are released prior to the FDIC hold.
Data Inaccuracy, Missing Codes and Mapping
The most common issue related to the Join file is missing beneficiary codes. Each Covered Institution should ensure that beneficiary codes are present for all accounts and explain how beneficiary information is sorted for each account. In the Join file, data fields 8. CS_Rel_Code and 9. CS_Bene_Code are usually inaccurate or missing. The Covered Institution should ensure there is a way to report beneficiary data.
In addition, Covered Institutions must ensure that Customer and Join files link properly. For example, fields 2 to 7 in the Join file should match fields 1 to 6 in the Deposit file exactly. Field 1 (1. CS_Cust_Identifier) of both the Customer and Join files should also match exactly.
Identify Sweep Investment Vehicle Products and Report in Sweep File
The most common issue related to the Sweep file is the failure to clearly identify Sweep Investment Vehicle products. The sweep products to be reported in the Sweep file are sweeps from FDIC-insured deposit accounts to investment accounts within the Covered Institution that are not FDIC-insured. A typical deposit account type involved in a sweep is a corporate DDA account. Sweep investment products include, but are not limited to, repurchase agreements (Repo), Eurodollar/Offshore, Fed Funds, Foreign Branch Deposits, IBF, and holding company commercial paper. Sweep investment balances and FDIC provisional holds which are calculated based on the sweep investment balance should both be reported in the Sweep file, not in the Deposit and Hold files.
A sweep arrangement that involves funds moving out of the Covered Institution should not be included for the purposes of this rule.
A deposit account to deposit account sweep should not be reported in the Sweep file. This includes zero-balance accounts or DDA to SAV sweeps, etc. All deposit accounts involved in a deposit to deposit sweep should be reported in the Deposit file. FDIC provisional holds calculated for these deposit accounts should be reported in the Hold file.
If the Covered Institution has sweep investment products, the deposit account linked to those investments needs to be marked as a “Y” in data field 42. DP_Sweep_Code of the Deposit file. This code gives the FDIC a clear indication that this deposit account has one or more sweep investment accounts linked to it.
Data accuracy and completeness
- 1. CS_Cust_Identifier: a Covered Institution should be able to report a unique and non-duplicated customer identifier. This data field allows Customer file to be linked to Join file.
- 2. CS_Tax_ID and 3. CS_Tax_Code: do not leave them blank
- Similar to Deposit file, the Customer file provides two sets of name and address data fields, one for parsed data, the other for unparsed data.
- If parsed name and address data fields are used, the city, state, zip, and country fields should be populated. The country name should be provided in the country name data field 23. CS_Country (up to 10 characters) or follow the IRS standardized codes.
All monetary values should not include plus “+” signs as a leading character. The only sign needed is the negative “-“sign when the amount is less than zero US dollars. Also, please do not pad with leading zeros and trailing zeros. All monetary values need to be reported in US dollars. If a currency conversion is needed, use a reputable source for conversion rates and store that rate so that it would be possible to convert the deposit amount back to the original currency type for processing. For example, to report an amount of $123,456.78, the deposit file record should look like |123456.78|, and not |+00000123456.7800|.
Mainframe EBCDIC to ASCII conversion
Please note special characters outside the ASCII Table may cause loading process to stop.
Test environment issues
Please note subsets of data in the test environment may cause linkage issue. Banks should monitor closely.
File format and choice of delimiter
The standardized data extract files are variable length delimited files. They are not in traditional mainframe fixed-length files. Both tab and pipe can be used as the delimiter. A Covered Institution should use the same delimiter in all files, including files from different systems. FDIC inbound files use pipe as the delimiter.