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TCH Responds to FDIC’s NPR Imposing New Deposit Insurance Recordkeeping Requirements on Large Banks

The ABA, TCH, the CBA, and SIFMA (Associations), filed a joint-trades comment letter responding to the FDIC’s NPR on recordkeeping for timely deposit insurance determination. The NPR seeks to ensure that, should a bank with a large number of deposit accounts fail, depositors would have prompt access to their funds post-failure. The Associations support this goal as a means to reinforce public confidence in the FDIC, bank deposits, and the U.S. banking system, and are committed to working with the FDIC to design and implement cost-effective solutions to achieve these ends. However, the Associations argue that the NPR does not appropriately balance the burdens and costs it would impose on covered banks and their customers on the one hand, and the limited improvements for resolving such a bank and expediting payments to its depositors on the other.