BPI submitted comments on the Federal Deposit Insurance Corporation on its Summary of Deposits (SOD) Survey, supporting the importance of the report and the value it provides to various stakeholders, and further encouraging the FDIC to make certain improvements. BPI would suggest that the FDIC (i) extend the due date of its SOD to at least 45 days after the June 30 as-of date, (ii) publish the Annual SOD Reporting Instructions and related FDIC Financial Institution Letters by mid-April to allow firms and software vendors adequate time to make necessary changes, (iii) update the edit check for addresses to ensure that submissions that include branch addresses consistent with those on the United States Postal Service’s website and that meet the standards of the FDIC’s approved vendor software do not produce errors, and (iv) consider ways to use more automated techniques to enhance SOD processes and related updates to FDIC records.
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