SPST-0099 - Renewal (2020) Final

SUPPORTING STATEMENT
REPORTING AND RECORDKEEPING REQUIREMENTS FOR BROKERED DEPOSITS
(OMB No. 3064-0099)
INTRODUCTION
The FDIC is requesting OMB approval for a three-year extension without revision to the
information collection, as captioned above. The current clearance expires on November 30, 2020.

A. JUSTIFICATION
1.

Circumstances and Need

In general, section 29 of the Federal Deposit Insurance Act prohibits undercapitalized
insured depository institutions from accepting, renewing, or rolling over any brokered
deposit. Adequately capitalized institutions may do so with a waiver from the FDIC. The
requirements for a brokered deposit waiver are found at 12 CFR 303.243.
2.

Use of Information Collected

The applicant is required to furnish information in letter form. Generally, the required
information pertains to the timeframe for which the waiver is requested; policies governing
the use of the deposits; the volume, rates, and maturities of deposits held and anticipated;
asset growth plans; procedures and practices regarding deposit solicitations; management
oversight of the solicitation, acceptance, and use of the deposits; the reasons the institution
believes its acceptance, renewal, or rollover of brokered deposits would pose no undue risk;
and a recent consolidated financial statement, including balance sheet and income statement.
The information furnished by the applicant is used by the FDIC as a basis for evaluating the
factors required by statute before approving the application. Specifically, the FDIC must
determine that the acceptance of such deposits does not constitute an unsafe or unsound
practice with respect to such institution.
3.

Use of Technology to Reduce Burden

The information is collected through FDICConnect, a secure interactive Website.
4.

Efforts to Identify Duplication

This collection does not duplicate information available elsewhere. The information is
unique to the occasion to which the application relates.
5.

Minimizing the Burden on Small Banks
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The information collected is only that required to evaluate the applicant, giving
consideration to the statutory factors enumerated in section 29 of the FDI Act.
6.

Consequences of Less Frequent Collections

The information is collected only when an adequately capitalized insured depository
institution wishes to accept, renew, or rollover brokered deposits.
7.

Special Circumstances

None.
8.

Consultation with Persons Outside the FDIC

A Federal Register notice seeking comment for this collection for a period of 60 days was
published on September 4, 2020 (85 FR 55287). No comments were received.
9.

Payment or Gift to Respondents

Not applicable.
10. Confidentiality
Information will be kept private to the extent allowed by law.
11. Information of a Sensitive Nature
No information of a sensitive nature is required.
12. Estimate of Annual Burden
2020 Summary of Annual Burden and Internal Cost (3064-0099)
Estimated
Estimated
Estimated
Frequency of
Type of Burden
Number of
Number of
Time per
Response
Respondents
Responses
Response
Re Application for Waiver of Prohibition on
Acceptance of Brokered Deposits
TOTAL HOURLY BURDEN
TOTAL INTERNAL COST*

Reporting
$104.15

15

1

6 hours

On Occasion

Total Annual
Estimated
Burden
90 hours
90 hours
$9,373.50

/HR

Total Annual Burden: 90 hours
The total estimated annual cost for all respondents is:

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90 hours x $104.15 = $9,373.50.
Summary of Hourly Burden Cost Estimate (3064-0099)
Estimated Category of
Personnel Responsible for
Complying with the PRA
Burden
Executives and Managers 1
Lawyers 2
Compliance Officers 3
IT Specialists 4
Financial Analysts 5
Clerical 6
Weighted Average

Total Estimated
Hourly
Compensation

Estimated Weights

$121.63
$149.39
$66.43
$91.05
$78.32
$32.99

55%
10%
10%
5%
10%
10%

Weighted Hourly
Wage
$66.90
$14.93
$6.64
$4.55
$7.83
$3.30
$104.15

Source: Bureau of Labor Statistics: "National Industry-Specific Occupational Employment and Wage
Estimates: Industry: Credit Intermediation and Related Activities (5221 And 5223 only)" (May 2019),
Employer Cost of Employee Compensation (June 2020), Consumer Price Index (June 2020).
Note: The 75th percentile wage information reported by the BLS in the Specific Occupational
Employment and Wage Estimates does not include health benefits and other non-monetary benefits.
According to the March 2020 Employer Cost of Employee Compensation data compensation rates for
health and other benefits are 33.9 percent of total compensation. Additionally, the wage has been
adjusted for inflation according BLS data on the Consumer Price Index for Urban Consumers (CPIU) so that it is contemporaneous with the non-wage compensation statistic. The inflation rate was
0.67 percent between May 2019 and June 2020.

13. Capital, Start-up, Operating, and Maintenance Cost Burden
None.
14. Estimated Annual Cost to Federal Government
None.
15. Reason for Change in Burden

1 Occupation (SOC Code): Management Occupations (110000).
2 Occupation (SOC Code): Legal Occupations (230000).
3 Occupation (SOC Code): Compliance Officers (131040).
4 Occupation (SOC Code): Computer and Mathematical Occupations (150000).
5 Occupation (SOC Code): Financial and Investment Analysts, Financial Risk Specialists, and Financial Specialists,
All Other (132098).
6 Occupation (SOC Code): Office and Administrative Support Occupations (430000).

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There is no change in the method or substance of the collection. The overall reduction in
burden hours of is a result of economic fluctuation. In particular, the number of respondents
decreased from 30 to 15, and the hours per response remained the same.
16. Publication
There is no publication of the information collected.
17. Display of Expiration Date
Not applicable.
18. Exceptions to Certification
None.
B.

STATISTICAL METHODS
Statistical methods are not employed in this collection of information.

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