Large-Bank Deposit Insurance Determination Modernization FAQs
Standard Data File Structure and Format
The rule requires an extract of depositor and customer data to be provided in a standard format in five files: Deposit, Sweep/Automated Credit Account, Hold, Customer and Deposit-Customer Join. Should all deposit accounts be reported in a single Deposit file or are multiple sets of files permissible?
All data could be provided through one set of files but multiple sets are permissible. Appendix H, “Possible File Combinations for Deposit Data,” to the rule provides requirements for multiple file sets.
The FDIC will want a data extract in a standard format by close of business the day following failure based on the close-of-business account balances on the day of failure. Would the FDIC request additional extracts of data for days subsequent to the date of failure?
The FDIC will not request additional data extracts on days subsequent to failure. Depending on the systems and procedures used by the Covered Institution, the Hold file provided the day following failure may not contain information on the FDIC provisional holds. If this is the case, a second Hold file should be generated which includes the provisional hold information.
Should the standard data file extracts be generated separately for each charter?
Yes. Each set of files generated should include data for only a single institution charter. For example, if a holding company has two affiliated Covered Institutions which both fail, it will be necessary to generate two sets of files, one for each Covered Institution.
If a Covered Institution does not have any sweep accounts or automated credit accounts, is it necessary to generate a Sweep/Automated Credit Account file?
Explain the possible options for the Hold file 8. HD_Hold_Reason, especially what is meant by “daily operational type” holds?
Generally, the FDIC is interested in receiving information on loan collateral and court ordered holds. Daily operational holds, such as those related to the check-clearing process, should not be included in the Hold file. The amount of the FDIC provisional hold posted to the account also should be reported in the Hold file.
What is the Deposit file 7. DP_Bank_No (Bank Number)? Is this a user defined Bank Number? Can this be an ABA number, software defined number or is this the FDIC Certificate Number?
7. DP_Bank_No is an internal bank number or such other identifier assigned by the Covered Institution.
For Deposit 15. DP_Prod_Cat, what value should be set for Escrow Accounts?
If the escrow accounts reside on the deposit system, then report them as they reside on your system, DDA or SAV, for example. If the escrow accounts reside on a loan system, these balances should not be reported on the Deposit file.
How should we report foreign addresses in the Deposit file?
When reporting a foreign address in the Deposit file described in Appendix C use the following logic:
- Ensure field 27. DP_Country, has the proper two character IRS Foreign Country Code Listing for Modernized e-File (MeF) or is specified otherwise using the 10 characters assigned to this field.
- Do not put values in fields 24. DP_City, 25. DP_State, and 26. DP_ZIP.
- Enter the Postal Code, City/Town/Locality, and Country in field 23. DP_Street_Add_Ln_3.
Can you clarify what “interest term” means in 39. DP_Int_Term_No of the Deposit file? Are you expecting us to report the actual interest payment frequency (for example, interest is paid daily, monthly, quarterly, yearly, etc.)?
39. DP_Int_Term_No (CD term) refers to the number of months for a CD (for example, 6 months, 12 months, 36 months or 60 months). To report a one-year CD, “12” should be entered in this data field. The payment frequency for interest or number of months until maturity is not captured in this field.
To convert a CD term from days to months, you should divide the days by 30, round down to a whole number and enter that number in field 39. For example, if the term is stated as 10 days, 10 divided by 30 yields 0.33 which would round down to zero; zero 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.
If the balance of an account is negative (the account is overdrawn), would the negative sign go at the beginning or end of the amount field?
We would like to see leading signs for negative values as follows: |-234.45|
If the file layout allows for 50 positions for a field and my system has only a 30 position field, do you want us to pad the remaining 20 positions with spaces?
Along the same lines, our numeric fields for the most part include leading zeroes. If you have a 25 position numeric field, and my matching field is 15 positions, can we send in the file:
For name fields or character fields, do not pad leading or trailing spaces. Instead of | John Doe |, you should simply put |John Doe|. For numeric fields, do not pad with leading or trailing zeros. For example, instead of |+0001234.56000|, you should simply report |1234.56|.
We produce our files to you in a "pipe delimited" ASCII file. If there is no information for a field you specified (for example, Account Identifier 2, 3, 4, etc.), do you want "pipe pipe" until we get to a field we have, or "pipe 25 char pipe 25 char" etc.?
If you have no information for a field we would prefer to see back-to-back pipes or TABs, whichever you use as the delimiter.
Should we provide the field lengths for our data?
It is not necessary for you to provide your data field lengths. We request that you provide the data formatted such that the field length is equal to or less than the requested length. Header and footer records are now optional. When the files are transmitted to the FDIC, we would like to see a control report showing the number of accounts that are provided along with balancing information that ties to the data you provided.
Regarding the accrued interest field on the Deposit file (36. DP_Acc_Int), for our time deposit accounts (TDA) accrued interest is updated in a weekly sequential pass. Therefore, it is possible accrued interest may not be current as of the close of business on the date of closure if that date does not coincide with the weekly TDA sequential. In order to provide the FDIC with accrued interest up to the date of closure, is it acceptable to combine the accrued interest with a projected interest amount for days from the date of the last sequential to the date of closure? If the date of closure happens to be the same as the date of weekly sequential, then the projected interest would be zero. The projected interest would be balanced to a system report which includes the projected interest in its accrued interest totals.
The FDIC requires a download of the accrued interest that balances to the trial balance report and general ledger as of the date of the data extract. The accrued interest field must be completed for the FDIC to load it into our system. If interest was paid through the date of closure, this field could potentially be zero.
Should forward accruals be backed out of the accrued interest field? For example, forward accruals can occur in a Friday weekly sequential pass to include Saturday and Sunday. Should the accrued interest be reduced for these days’ accruals?
No, forward accruals should not be backed out.