Part 370 requires two annual reports to be generated by covered institutions, and while the general requirements for each are laid out in the rule, there is little specificity about how the reports must be structured or formatted. We have experience designing reports to accommodate banking regulators and is positioned to help a company design […]
Posts Tagged ‘Banks’
File Generation For FDIC Part 370
The FDIC requires a set of four files to be available within 24 hours of a bank’s failure, and responding companies must design how these files will be generated, stored, and transmitted. Having the data available to respond is a critical first step, but thought must put into how the company will actually take that […]
FDIC Part 370 Implementation Road Map
Evaluating where a bank stands today and where it needs to be in relation to Part 370 is of paramount importance in the early phase of the company’s response to the FDIC. Putting together a coherent road map that lays out concrete projects to be undertaken will allow the company to mount a coordinated response […]
FDIC Part 370 Readiness Evaluation
The first thing any bank has to do in its response to Part 370 is evaluate its current state of readiness. We are well positioned to help firms assess readiness along a number of dimensions: Data availability and reliability Systems architecture Infrastructure Organizational structure We have helped dozens of organizations, both within financial services and […]
Data Stewardship For FDIC Part 370
The basis for any response to Part 370 will be a thorough analysis of customer, account, and deposit data across the organization. This can be a massive undertaking at an organization the size of those targeted by Part 370. We have led dozens of data analysis and remediation efforts across industries, including: System identification: Looking […]
FDIC Part 370: Support On-site FDIC Inspections
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 support on-site FDIC inspections. In addition to the annual certification and report, the FDIC will conduct on-site testing of institutions’ compliance with Part 370. While it has not defined […]
FDIC Part 370: Implement FDIC-Required Calculations And Reports
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 implement FDIC-required calculations and reports. Once an organization has determined that it is able to meet the requirements of Part 370, it must go about designing their interfaces with […]
FDIC Part 370: Manage Customer Access To Funds
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 […]
FDIC Part 370: Manage And Maintain Customer And Deposit Data
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 and maintain customer and deposit data. Once a bank has identified existing customer and deposit data and laid out a plan for remediating deficiencies, it must define a […]
FDIC Part 370: Identify Data Sources And Remediate Data
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 identify data sources and remediate data. For the largest and most complex depository institutions, account and customer data can be spread across dozens or even hundreds of backend systems. […]
What FDIC Part 370 Means For Large Banks
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, […]
The 10 Parts Of FDIC Part 370
Part 370 is broken into 10 parts, as follows. 370.1 Purpose and scope The purpose of Part 370 is to improve the FDIC’s ability to fulfill its two mandates related to paying deposit insurance: Pay deposit insurance as soon as possible after the failure of a covered bank; and Resolve a covered institution with the […]