TCH Joins ABA and CBA in Comment Letter on the FDIC’s Deposit Insurance Determination Modernization ANPR

The Clearing House Association (TCH) joined the ABA and CBA in filing a comment letter on the FDIC’s deposit insurance determination ANPR originally issued in April. The ANPR asks whether the FDIC should require banks with a large number of deposit accounts (covered banks) to (i) enhance their recordkeeping to provide the FDIC with better information about each depositor’s ownership interest in different accounts and (ii) be able to calculate insured and uninsured amounts for each depositor at the end of each business day. As a general matter, the letter asserts that covered banks will ultimately be prepared to meet the FDIC’s policy objectives as set forth in the ANPR provided the FDIC (i) allows sufficient development and implementation time, (ii) provides details of how insurance determination computations are to be performed, and (iii) works closely with each covered bank throughout the process.