Request for Information on Deposits

I am supportive of the Request for Information (RFI).  I think soliciting input on the behavior and characteristics of different types of deposits, including in particular differentiating among types of uninsured deposits, is a helpful step by the agency.1  More generally, I think regulators need to think more holistically about the deposit landscape than we do today,2 and I view this RFI as a small step in the right direction.  In the long run, we should consider whether, how,3 and to what extent to collect more granular and frequent deposit data, and I think asking for broad feedback before proposing specific Call Report changes is useful.4  Finally, while any potential deposit insurance reform would ultimately be decided by Congress, I think seeking input from the public on the issue is constructive.

• 1

  And a contrast to certain actions taken last year. See, e.g., Federal Deposit Insurance Corporation, Special Assessment Pursuant to Systemic Risk Determination, 88 Fed. Reg. 88,329 (Nov. 29, 2023).

• 2

  See Travis Hill, Reflections on Bank Regulatory and Resolution Issues (July 24, 2024) (“I do think we should make an effort to modernize how we think of a bank’s funding mix, and to think more holistically about how we view a bank’s deposit franchise.”).

• 3

  See, e.g., Federal Deposit Insurance Corporation, Rapid Phased Prototyping Initiative (March 26, 2021) (FIL-19-2021).

• 4

  As noted in the RFI, it also worth considering whether there are existing reporting elements that should no longer be collected.