Large Bank Deposit Insurance Determination Modernization
Miscellaneous Account Handling
January 25, 2016
Rule provisions attempt to protect funds that may be determined to be excess from leaving the financial institution during the period between the institution closing date and when a final insurance determination may be made. Attributes of accounts that fit this format follow:
- Balances are on deposit systems
- Balances are accessible by customers
- There is a reasonable likelihood that the accounts, when combined with other accounts for the same customer, could result in excess deposit balances, e.g. more than $ 250,000
- The accounts are serviced by a system that is integrated with other deposit applications
- The balances are included as deposits on the Call Report or TFR and subject to insurance assessments
Following is a table of accounts where institutions have asked for guidance regarding treatment for provisional hold processing and whether the accounts should be included in data downloads. The list will be expanded with additional account types through time.
|Account Type||Account Location||Provisional Hold||Data Download (a)|
|Prepaid Gift Cards||GL||N||N|
|Prepaid Gift Cards||DDA||N||Y|
|Prepaid Payroll Cards||GL||N||N|
|Prepaid Payroll Cards||DDA||N||Y|
|GL Suspense Accounts||GL||N||N|
|Credit Card Overpayments||GL||N||N|
|Health Savings Accounts||GL||N||N|
|Health Savings Accounts||DDA||N||Y(b)|
|Prepaid Loan Expenses||GL||N||N|
|Loan Proceeds in Process||GL||N||N|
(a) To the extent any deposit account is part of a deposit application whose balance resides on a deposit system and is included with normal deposit trial balances and reporting, that account balance would generally be subject to provisional hold and reporting requirements under the rule.
(b) If the DDA account represents a summary of many individual accounts, include the account as a single total on the download. In anticipation of closure the FDIC would request a file containing details of the account including the account holder’s name, related deposit account number, and amount of the balance attributable to the account holder.
A number of these accounts may reside on external systems with only summary posting totals to the institutions’ general ledger. In a majority of those situations, such as credit card overpayments, these accounts would not be subject to provisional holds nor would they be included in deposit file downloads prepared for the FDIC. They may, however, be scrutinized more closely in the event of failure.
Accounts that would not be in scope generally include GL accounts used as clearing accounts for unposted items.
Credit card, prepaid card, payroll card, gift card, and other similar accounts would generally not be covered due to the small balances and inaccessibility to owner information.
Balances representing government benefits payable, such as food stamps, child support, and similar programs would not be covered.
Balance representing health benefits payable to employees would generally not be covered.
The foregoing only applies to compliance with rule provisions. Closing procedures would address several of these types of accounts individually.