Aug 6 -- The Federal Deposit Insurance Corporation (FDIC) is soliciting comments from interested parties on deposit data that is not currently reported in the Federal Financial Institutions Examination Council's (FFIEC) Consolidated Reports of Condition and Income (Call Report) or other regulatory reports, including for uninsured deposits. The FDIC seeks information on the characteristics that affect the stability and franchise value of different types of deposits and whether more detailed or more frequent reporting on these characteristics or types of deposits could enhance offsite risk and liquidity monitoring, inform analysis of the benefits and costs associated with additional deposit insurance coverage for certain types of deposits, improve risk sensitivity in deposit insurance pricing, and provide analysts and the general public with accurate and transparent data. Comments must be received on or before October 7, 2024.
The bank failures that occurred in March 2023 and subsequent events renewed focus by financial regulatory agencies, banks, investors, and the public on deposit insurance coverage, bank funding concentrations, and certain banks' reliance on uninsured deposits. While banks are required to provide certain data on deposit liabilities on the Call Report, they do not report comprehensive data on the composition of insured and uninsured deposits. Through this request for information, the FDIC is seeking to further evaluate whether and to what extent certain types of deposits may behave differently from each other, particularly during periods of economic or financial stress.
Specifically, the FDIC is soliciting comments on deposit data that is not currently reported in the Call Report or other regulatory reports, including for uninsured deposits, to gather information on the characteristics that affect the stability and franchise value of different types of deposits and whether more detailed or more frequent reporting on these characteristics or types of deposits could enhance offsite risk and liquidity monitoring; inform analysis of the benefits and costs associated with additional deposit insurance coverage for certain types of deposits; improve risk sensitivity in deposit insurance pricing; and provide analysts and the general public with accurate and transparent data. . . .
-- Questions on Banks' Internal Deposit Information
Question 1: How do banks measure or evaluate the stability of different types of uninsured deposits? For example, do banks measure or track characteristics such as length or type of depositor relationship, duration, depositor proximity, or rates paid by account type?
a. What are the different types of collateralized or secured deposits and what are the reasons for collateralization? Do banks monitor the uninsured portion of collateralized or secured deposits separately from the insured portion?
b. How do banks monitor intercompany deposits such as deposits with affiliates, subsidiaries, sweep deposits, or any bank-owned deposit account?
c. How do banks measure or evaluate the stability of operational deposits and non-operational deposits?
d. To what extent, if any, do banks rely on deposit categories as defined for regulatory reporting to determine stability?
e. Is there additional data on uninsured deposit components that banks collect and maintain internally?
f. What additional information would be helpful to the FDIC, the banking industry, and the public in demonstrating the stability of uninsured deposits?
Question 2: What are the challenges in calculating and reporting uninsured deposits on the Call Report?
a. How do banks estimate uninsured deposits for omnibus and other accounts that contain deposits owned by various parties where the underlying customer data is not maintained by the bank?
Question 3: As discussed in the appendix, 12 CFR part 370 (part 370) generally requires covered institutions to maintain complete and accurate records regarding the ownership and insurability of deposits (except as otherwise provided) and to have an information technology system that can be used to calculate deposit insurance coverage in the event of failure. These capabilities would facilitate the FDIC's prompt payment of deposit insurance and enhance the FDIC's ability to implement the least costly resolution of these covered institutions. However, the FDIC understands that some institutions that are subject to the requirements of part 370 do not necessarily use information from their part 370 recordkeeping and insurance calculation capabilities for purposes of reporting uninsured deposits on the Call Report. For some part 370 covered institutions, what is the reasoning for not using the same methodology from their part 370 recordkeeping and insurance calculation capabilities to report uninsured deposits on the Call Report?
a. For part 370 covered institutions, how long would it take to effectively use part 370 calculation-generated insured and uninsured information to report data on Call Report Schedule RC-O,—Other Data for Deposit Insurance Assessments, instead of other estimated measures?
b. Where other estimated measures are used, has analysis been performed to evaluate the margin of difference between those estimates and the calculation produced using part 370 capabilities? If so, what are those margin differences?
c. Do institutions collect additional deposit information from customers that is not reported in part 370 output files (e.g. customer classifications, account categorizations, etc.)
Question 4: For what other types of deposits, which are not already reported on the Call Report or other data collections, do banks collect and maintain data internally and at what frequency?
a. How are these types of deposits defined?
b. How does data on these types of deposits help inform analysis of bank liability structure, risk, and funding stability?
c. Of the data collected and maintained internally, what information could be provided at little or no burden? What challenges may occur in reporting this information?
d. Of the information collected and maintained internally, what information could be provided pertaining to foreign deposits and how the deposits are payable (dually or not dually payable)?
-- Questions on Potential Additional Data Items
Question 5: What, if any, additional data, including more granular or more frequently reported data, should the FDIC, in conjunction with other members of the FFIEC, consider collecting on the Call Report or another data collection to better inform the public and agencies' understanding of different types of depositor behavior? What specific additional data, such as length or type of depositor relationship, duration, depositor proximity, or rates paid by account type, would be the most helpful to collect, if any?
a. Should data collections include particular types of deposits or uninsured deposits? If so, which types and at what frequency? What are the benefits or challenges of maintaining and reporting average values of such data for a given frequency?
b. Should data collections include different measures of concentrations of deposits, such as by deposit account size, depositor type, or industry? If so, which thresholds, types, and industries are appropriate and why?
c. Should collection of additional data be limited to certain reporting thresholds, based on, for example, consolidated asset size, amount of the item to be reported, or some other activity-based threshold? Why or why not? What type of burdens would collection of additional data place on institutions?
d. Should collection of any additional, more granular, data on deposits be afforded confidential treatment? If so, please explain why.
e. To what extent should data collections require consistency across different definitions and information reported on deposits, including deposit liabilities, operational deposits, and other types of deposits, between the Call Report and other data collections?
f. How helpful would standardized reporting definitions, including for operational and non-operational deposits, be to the FDIC, the banking industry, and the public?
g. If the agencies were to consider collecting additional information, is there any information that the agencies currently collect that commenters believe is less useful, overly burdensome, and should no longer be collected?
-- Questions on Deposit Data To Inform Conversations on Deposit Insurance Coverage
As mentioned in section II.B. of this document, the May 2023 report, “Options for Deposit Insurance Reform,” notes that Targeted Coverage would provide substantial additional coverage to meet ongoing payment and operational needs of businesses, which is expected to yield large financial stability benefits relative to its costs. However, Targeted Coverage is one of three options examined in the report, and each option has strengths and weaknesses. The proposed options require an act of Congress.
Question 6: If Congress were to consider deposit insurance reform, what are the pros and cons of the options described in the FDIC's May 2023 report? Do commenters have additional data that could help inform the discussion?
Question 7: If Congress were to pursue increased coverage for particular types of deposit accounts, but not all deposits, what type of deposits should be included?
Question 8: If Congress were to pursue increased coverage for “business payment accounts,” as described in the May 2023 report, what are the specific definitions commenters would recommend and why?
a. What features of an account would indicate that it is a “business payment account,” and are these features quantifiable and readily available?
b. Should such a definition be limited to coverage of accounts linked to payroll at businesses, include accounts linked to operations such as payroll, or otherwise be defined? Should such a definition consider the existing definition for “operational deposits,” as defined in 12 CFR 329.3?
Question 9: What burden or challenges would be associated with providing new deposit data items, such as “business payment accounts” or similar accounts linked to payroll, vendors, or operations?
-- Other Comments
Question 10: Please provide any other comment or information that would be useful for the FDIC to consider.
FRN:
https://www.federalregister.gov/d/2024-17298