Simplification of Deposit Insurance Rules

Mr. James P. Sheesley
Assistant Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429

Attention: Comments RIN 3064–AF27

Dear Mr. Sheesley: 

The American Bankers Association, Bank Policy Institute, and Mortgage Bankers Association (collectively, the Associations) appreciate this opportunity to comment on the proposal from the Federal Deposit Insurance Corporation (FDIC) to simplify certain deposit insurance regulations. The Associations and our members agree that the proposed amendments to 12 CFR §330.10, 13, and 7(d), for deposit accounts of revocable trusts, irrevocable trusts, and mortgage servicing, respectively, will help simplify these complex rules. However, we urge the FDIC to modify the proposal to address the concerns outlined below and to incorporate clarifications and examples
that would enhance the understanding of insurance coverage by bankers and their customers.

In addition, institutions subject to the FDIC’s rule 12 CFR Part 370 report that, while they support the proposed changes to the deposit insurance rules, introduction of the proposal has disrupted efforts to implement this inaugural regulation. They note challenges in deciding whether to continue to update data and processes based on the current rules or wait to see how and when these rules may change. To address these issues, we suggest accommodations for these institutions in light of the proposal.

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