InfoBytes Blog
FDIC grants exception requests for certain deposit insurance recordkeeping requirements
On August 4, the FDIC published responses to exception requests pursuant to the Recordkeeping for Timely Deposit Insurance Determination rule (Rule). The notice outlines two time-limited exceptions for covered institutions effective as of July 28. The Rule, codified at 12 CFR Part 370 (and amended last year—covered by InfoBytes here), requires covered institutions to implement information technology systems and recordkeeping capabilities in order to calculate quickly the available amount of deposit insurance coverage for each deposit account in the event of failure. The FDIC allows covered institutions to request an exception from one or more of Part 370’s requirements should circumstances “make it impracticable or overly burdensome to meet those requirements.” Additionally, a covered institution may—upon notice to the FDIC—rely upon another covered institution’s FDIC-granted exception request, if the two institutions have substantially similar facts and circumstances.
The first exception grants an exception of up to 18 months from certain information technology and general recordkeeping requirements to allow covered institutions to perform system updates and remediation efforts to ensure certain sole proprietorship deposit accounts are correctly classified by an institution’s information technology system. The second exception grants an exception of up to 12 months from certain information technology and general recordkeeping requirements “for a limited number of joint accounts that a covered institution has not confirmed are ‘qualifying joint accounts’ entitled to separate deposit insurance coverage.”