1550-0023 (Schedule DI--Supporting Statement)

SUPPORTING STATEMENT
OMB Control No. 1550-0023
Thrift Financial Report: Schedule DI

A.

JUSTIFICATION

1.

Circumstances and Need

The Office of Thrift Supervision (OTS) collects financial data from insured savings
associations, which are used to regulate and supervise the industry and to develop policy. The
vehicle used to collect these data is the Thrift Financial Report (TFR). OTS collects financial
data from insured savings associations, their subsidiaries, and their holding companies in order
to assure their safety and soundness as depositories of the personal monies of the general public.
On March 14, 2006, the Federal Deposit Insurance Corporation (FDIC) Board of
Directors approved interim final rules pursuant to the Federal Deposit Insurance Reform Act of
2005 (Reform Act), Pub. L. No. 109-171, that will raise the deposit insurance coverage on
certain retirement accounts at a bank or savings institution to $250,000 from $100,000. The
increase, which became effective on April 1, 2006, is the result of a new law increasing federal
deposit insurance coverage for the first time in more than 25 years. The basic insurance
coverage for other deposit accounts for individuals, joint accountholders, businesses,
government entities, and trusts - remains at $100,000.
Under the FDIC's new rules, up to $250,000 in deposit insurance will be provided to a
depositor with money in a variety of retirement accounts, primarily traditional and Roth IRAs
(Individual Retirement Accounts), at one insured institution. Other types of accounts included
under the new deposit insurance limit are self-directed Keogh accounts, "457 Plan" accounts for
state government employees, and employer-sponsored "defined contribution plan" accounts that
are self-directed, which are primarily 401(k) accounts. In general, self-directed means the
consumer chooses how and where the money is deposited. In addition, the IRAs and other
retirement accounts that will be protected under the new rules to $250,000 are insured separately
from other accounts at the same institution that will continue to be insured up to at least
$100,000.
The new law also established a method by which the FDIC would consider an increase in
the insurance limits on all deposit accounts (including retirement accounts) in the future, but
only every five years starting in 2011. Any such increase would be based, in part, on inflation.
Otherwise, accounts will continue to be insured as described above. Moreover, the new law also
merged the Bank Insurance Fund and the Savings Association Insurance Fund into a new
Deposit Insurance Fund.
As a result of these changes in deposit insurance for retirement accounts held at FDICinsured depository institutions, OTS considered a range of potential information needs and
identified those additions to the TFR that are believed to be most critical and relevant to OTS as
it seeks to fulfill its supervisory responsibilities. At the same time, OTS identified certain

existing TFR data that are no longer relevant or useful to warrant their continued collection.
OTS believes that the reporting burden that would result from the new TFR items discussed in
this proposal would increase only slightly due to the proposed elimination of a limited number of
other TFR items. After savings associations make any necessary changes to their systems and
records, OTS estimated that these deposit-related reporting changes would produce an average
net increase of 0.4 hours per institution per year in the ongoing reporting burden of the TFR.
Nevertheless, when viewing these proposed revisions to the TFR within a larger context, they are
intended to maintain the effectiveness of the on- and off-site supervision activities of the OTS,
which should help to control the overall regulatory burden on institutions.
2.

Use of Information Collected

OTS uses this information to monitor the condition, performance, and risk profile of
individual institutions and systemic risk among groups of institutions and the industry as a
whole.
3.

Use of Technology to Reduce Burden

Since 1993, all reporting associations file their TFRs electronically. Electronic
transmission of regulatory reports has significantly reduced reporting burden, and has improved
data quality by reducing transcription errors and providing edit checks at the source of data
entry.
OTS internally developed and maintains the Microsoft Windows-based electronic filing
software and provides it free of charge to all its reporting institutions via CDROM, including
incremental updates via the Internet. The electronic software brings forward institution
structural information and beginning balances. The software also calculates certain fields, sums
totals, as well as provides capabilities for importing data from external sources, and exporting
data for external review/preparation. OTS estimates that the need for data entry is reduced
approximately 20 percent by these automatic features in its software.
There are over 900 data edits in the electronic software that allow associations to validate
their data prior to transmitting the report. The software allows associations to explain reasons
for edit exceptions in a memorandum system called "User Notes." Incorporating all edits used
by OTS into the electronic filing software has ensured data quality and significantly reduced the
amount of time OTS staff spends validating the data. This substantially reduces the need for
phone calls to reporting institutions further lessening reporting burden on the industry.
In March 2004, OTS enabled institutions to submit their regulatory filings using the
Internet. Industry feedback indicated that Internet communications reduced the technological
burden of regulatory filing responsibilities.
Burden reduction through the use of technology is an ongoing initiative of OTS. Industry
feedback on newly introduced software features, enhancements, and improvements consistently
indicates a large degree of success in this effort.

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4.

Efforts to Identify Duplication

This information collection is not duplicative within the meaning of the PRA and OMB
regulations. Information that is similar to or that corresponds to information that could serve
OTS's purpose and need in this information collection is not being collected from OTS regulated
institutions by any other means or for any other purpose; nor is this information otherwise
available in the detail necessary to satisfy the purpose and need for which this collection of
information is undertaken. However, the data gathered in this information collection are shared
with the other Federal financial institution regulators, state financial institution regulators, and
other Federal agencies.
5.

Minimizing the Burden on Small Firms

Although the collection of information affects a significant number of small businesses,
OTS does not anticipate that the net economic impact will be large.
6.

Consequences of Less Frequent Collection

Collection of this information less frequently than quarterly would hinder the ability of
OTS to monitor the industry and perform its supervisory function.
7.

Special Circumstances
This collection meets the guidelines in 5 C.F.R. Part 1320.

8.

Consultation with Persons Outside the OTS

On April 28, 2006, OTS requested public comment for 60 days (71 FR 25282) on
proposed revisions to Schedule DI of the TFR. The notice described regulatory reporting
revisions proposed for the TFR: Schedule DI – Consolidated Deposit Information to become
effective September 30, 2006, primarily in response to the increased levels of deposit insurance
from $100,000 to $250,000 for retirement accounts provided by the FDIC Board of Directors on
March 14, 2006, in interim rules effective April 1, 2006 (71 FR 14629), implementing certain
provisions of the Reform Act.
OTS received comments on the April 2006 proposal from the American Bankers
Association (ABA), a trade group whose members include savings associations. OTS also
received a request from the Board of Governors of the Federal Reserve System to maintain line
DI200, IRA/Keogh Accounts, for their use in monetary analysis.
OTS has considered these comments and has decided to proceed with the proposed
changes to Schedule DI, but will not eliminate line DI200, IRA/Keogh Accounts. These changes
will become effective on December 31, 2006. This decision is discussed below.
ABA expressed concern about the short amount of time for savings associations to
implement the revisions. ABA urged OTS to delay the reporting revisions until the FDIC
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finalizes its interim rule on retirement deposit account insurance and savings associations have
had time to make necessary systems changes. The ABA noted that the amount of time that
institutions have to prepare for these reporting revisions is shorter than usual and indicated that
thrift deposit records and systems do not clearly distinguish the types of retirement deposit
accounts eligible for the higher insurance coverage from other accounts. It also asserted that
there is uncertainty in the thrift industry as to which retirement deposit accounts are eligible for
the higher insurance coverage. To address these concerns, OTS will set the effective date of
these changes at December 31, 2006.
For the December 31, 2006, TFR, thrifts would be expected to have made appropriate
systems changes to enable them to report reasonably accurate data on all types of retirement
deposit accounts eligible for the $250,000 insurance coverage. Thrifts’ deposit records and
systems should enable them to report information on all retirement deposit accounts in these
TFR items in accordance with the applicable instructions.
9.

Payment of Respondents
OTS provides no payment or gift to respondents.

10.

Confidentiality

OTS does not include in the TFR instructions any explicit guarantee of confidentiality of
this information. All but a very limited number of TFR data items, are available to the general
public. Data from Schedule DI, including the proposed changes, are available to the general
public.
11.

Information of a Sensitive Nature

The TFR form does not request any information that could be considered personally
sensitive.
12.

Estimate of Annual Burden

OTS estimates 854 savings associations (“respondents”). The total annual hour burden to
the respondents is estimated at 124,684, representing 4 submissions per respondent at 36.5 hours
each submission.
854 savings associations x 36.5 hours = 31,171 hours per response
31,171 hours x 4 submissions per year = 124,684 hours.

13.

Estimate of Annual Cost

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The cost to the thrift industry for the reporting burden of quarterly TFR schedules,
including Schedule DI, is $3,117,100.
The burden per report was derived by multiplying the number of items requiring input by
the number of reports per year, with appropriate adjustment of especially difficult items.
Variation in burden among reporting associations exists depending on the extent to which their
activities require an entry in every item requested on the reporting form, the complexity of
calculating the entry for an individual association, and the extent to which their own accounting
systems conform to the requirements of the reporting form.
14.

Estimates of Annualized Cost to Government
The total annualized cost to the federal government will be minimal.

15.

Reason for Change in Burden

This submission reflects a slight increase in individual institution burden (from 36.4 to
36.5), but a net decrease in total industry burden (from 128,128 to 124,684), due to fewer
respondents (from 880 to 854).
16.

Publication

OTS publishes a series of statistical reports of aggregate data on a national and
geographical area basis. Financial institutions, investment consultants, real estate consultants,
brokers, and appraisers as well as other Federal and state government agencies and institutions of
higher learning use the publications. These statistical reports are an adjunct to the data collected,
which are primarily for supervisory purposes.
17.

Expiration Date

OTS has received permission to not display the expiration date on this form. This form is
revised and issued annually. The expiration date will not assist the public in determining if this
is the correct form to be used when filing with OTS. In addition, OTS distributes copies of the
current form to all institutions and other interested parties and posts it on the OTS web site
whenever the report is changed.
18.

Exceptions
Not applicable.

B.

COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
Not applicable.

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