FDIC: Large-Bank Deposit Insurance ANPR

ABA Contact: Rob Strand
Published: 70 Federal Register 73652, December 13, 2005
Comments Due: March 13, 2006
Disposition: ABA and ACB Comments Filed March 13, 2006


The FDIC issued this advance notice of proposed rulemaking to solicit comment on the best approach to improve the deposit insurance determination process as it relates to banks with total number of deposit accounts over 250,000 and total domestic deposits of at least $2 billion. Currently, this covers 145 institutions.

The FDIC solicits response to three options which approach the determination process by 1) modifying computer systems to place a hold on portions of large deposit accounts with extensive depositor data available at the FDIC and 2) modifying the process so as to only require data set information currently available and 3) modifying the process as in 1 or 2 above while requiring that the largest 10 or 20 institutions know the insurance status of depositors at any given point in time.

In a joint letter with America's Community Bankers and the Financial Services Roundtable, the ABA discussed the value of the federal insurance system to maintain liquidity and confidence in any bank failure without fully protecting uninsured depositors as an enhancement of market discipline and a promoter of financial system stability. At the same time the letter questioned the benefit of the system suggested in the ANPR in comparison to the costs imposed on the banking industry. The letter urged the FDIC to reconsider proceeding further with the project.

Update: In response to the comments received, the FDIC issued a second Advance Notice of Proposed Rulemaking. See the ABA comment letter on the second ANPR.

2006 Regulations Chart
Federal Register
ABA Comment Letter