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.
You Might Also Be Interested In...
Resolution & Recovery Planning Putting “Too Big to Fail” to Rest: Evidence from Market Behavior in the COVID-19 Pandemic
Resolution & Recovery Planning BPI, FSF Comment on FSB Solvent Wind-Down and Resolution Disclosure Consultations
Resolution & Recovery Planning BPI Submits Comment Letter to Fed, FDIC on Resolution Planning Requirements
Resolution & Recovery Planning BPI Joins SIFMA and ABA In Filing Comment Letter On Proposed Amendments to 165(D) Rule
Resolution & Recovery Planning BPI and SIFMA submitted a comment letter to the OCC on its proposal to raise the asset threshold for its national bank recovery planning requirements
More Posts by This Author
Bank Conditions and Credit Availability Time To Return To the Regular Rulebook – Economic Uncertainty Is Not Extraordinarily Elevated
COVID-19 Relief BPI and Coalition of Trades Advocate for Economic Impact Payment Protections in American Rescue Plan Act of 2021