Currently, the FDIC estimates that the 38 largest banks will fall under the rule’s provisions. Those banks have until April 1, 2020 to either be in compliance or have secured any relevant exceptions or exemptions. In order to be in compliance, covered institutions will have to implement a change program that encompasses the people, processes, and technology necessary to:
- Identify data sources and remediate data
- Manage and maintain customer and deposit data
- Manage customer access to funds
- Implement FDIC-required calculations and reports
- Support on-site FDIC inspections
Each of these areas must be addressed in the lead-up to the compliance date. Some institutions will be further along than others in select areas, but every bank will have some degree of work to do to be in compliance by 2020. The ideal response would combine all the areas under a holistic Part 370 response program, centrally managed and sponsored by key stakeholders from business, operations, and technology, and incorporating critical input from legal, risk, and compliance.
If you are interested in learning more about FDIC Part 370 and how we can help you comply with the rule, please download our comprehensive guide or complete the contact form at the bottom of this page.