The Federal Deposit Insurance Corporation’s (FDIC) new recordkeeping requirements have shifted the responsibility for determining deposit insurance coverage from the FDIC to those insured depository institutions (IDIs) or Covered Institutions (CIs) subject to 12 CFR Part 370 (Part 370 or the Rule). Referred to as the "Recordkeeping for Timely Deposit Insurance Determination" rule, Part 370 is intended to ensure that depositors have prompt access to their insured funds in the event of a large bank failure.
The Rule requires CIs to configure their information technology (IT) systems to capture, assess, calculate, and report deposit insurance coverage. While there are opportunities to leverage data transformations required by other regulations, Part 370 introduces significant complexities that will fully engage CIs over the allotted three-year implementation period.
Specifically, CIs must address the treatment of products with deposit characteristics, unrefined and/or incomplete customer data that may not have been effectively captured at account establishment, a 24 hour window to substantiate insured versus uninsured amounts, and the integration of multiple internal and external sources.