In order to comply with FDIC Part 370, covered institutions will have to implement a change program that encompasses the people, processes, and technology necessary to manage customer access to funds.
In the event of a failure, the bank’s systems must be able to apply provisional holds on deposit accounts to allow the FDIC to make deposit insurance determinations. Additionally, once the holds are removed, the bank would have to have the ability to debit uninsured money from the account so the customer does not have access to those funds. These functions must be available on an individual account level in case deposit insurance determinations cannot be made within 24 hours for certain accounts.
While banks were required to have similar functionality in place as part of rule 360.9, each should assess their current functionality as it relates to the new rule. The FDIC has said that it will offer additional guidance on this requirement, so banks should be prepared to respond to any new information.
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