Robert E. Feldman
Executive Secretary
Federal Deposit Insurance Corporation
550 17th St., NW
Washington, DC 20429
Re: Part 327 – Certified Statements
Dear Mr. Feldman:
The Independent Community Bankers of America (ICBA)1 appreciates
the opportunity to comment on the Federal Deposit Insurance Corporation’s
(FDIC) proposal to modernize and simplify its deposit insurance assessment
regulations governing the use of certified statements. Under the proposal,
insured institutions would obtain their certified statements on the Internet
via the FDIC’s transaction-based e-business website, FDICconnect.
ICBA generally supports the FDIC’s proposal.
Overview
Under the Certified Statement Invoice proposal, there would be no need
for a bank to certify the accuracy of the information in the certificate
or invoice by signing the form and returning it to the FDIC before
payment is made, as is currently required. Instead, the bank would
access its statement online. If the invoice is correct, the bank
would simply pay it by funding its designated account and permitting
the
FDIC’s direct debit and retain the invoice for its files.
If the invoice is not correct, the bank would pay the amount specified
and either correct the erroneous information on the Call Report or amend
the invoice to show the desired change, sign it and return it to the
FDIC within the specified time frame. For incorrect invoices, these actions
would automatically constitute appeal of the assessment amount.
ICBA Comments
Community banks generally do not consider the current procedure to
be burdensome or unnecessarily cumbersome. Nonetheless, they, and
the
ICBA, support automating and streamlining the invoice assessment
system. However, as some banks may not have ready access to the Internet,
ICBA
recommends that the FDIC offer alternative means for those banks.
ICBA recommends such alternatives as fax or mail at the bank’s option.
For banks that use the new system, ICBA also strongly recommends that
the FDIC send an automated email to banks to notify them when their
invoices are available online. Such email notification would ensure
that banks do not neglect to check their certified statements online
or overlook funding their account in a timely manner for the FDIC’s
direct debit.
ICBA also supports the new system of filing an appeal by correcting
the Call Report or amending the invoice, as it eliminates an added step
in the appeals process since the amendment of the Call Report or the
returning of the invoice noting the discrepancy would constitute the
appeal.
Conclusion
ICBA supports the FDIC’s proposal to automate the certified statement
invoice assessment process. If the proposal is instituted, ICBA strongly
promotes the addition of a notification email sent to banks alerting
them that their certified statement invoice is available online.
Thank you for the opportunity to comment. If you would like further
information on this subject, please contact Chris Cole, ICBA Regulatory
Counsel, at 202-659-8111 or chris.cole@icba.org.
Sincerely,
Karen M. Thomas
Executive Vice President
Director, Regulatory Relations Group
_______________________________
1 ICBA
represents the largest constituency of community banks in the nation
and is dedicated exclusively to protecting the
interests of the community banking industry. We aggregate the power
of our members to provide a voice for community banking interests in
Washington, resources to enhance community bank education and marketability,
and profitability options to help community banks compete in an ever-changing
marketplace.